btc project environmental and social annual report (operations … · 7.3 training ... - carbon...

BTC Project

Environmental and Social Annual

Report (Operations Phase)

2009

BTC Pipeline Project

i

TABLE OF CONTENTS

EXECUTIVE SUMMARY .............................................................................................. 1

1 INTRODUCTION...................................................................................................... 2

2 ESIAs / EIA AND PERMITTING .............................................................................. 2

2.1 SUMMARY OF ANY MATERIAL MODIFICATIONS TO THE ESIAs ............................ 2

2.2 SUMMARY OF MATERIAL PERMITS ISSUED IN 2009 .............................................. 2 2.2.1 AZERBAIJAN ................................................................................................................ 2 2.2.2 GEORGIA .................................................................................................................... 2 2.2.3 TURKEY ...................................................................................................................... 2

2.3 UPDATE ON STATUS OF PROJECT SPECIFIC REQUIREMENTS FOR FURTHER WORK UNDER THE ESIAs OR PERMITS .................................................. 3

2.3.1 AZERBAIJAN ................................................................................................................ 3 2.3.2 GEORGIA .................................................................................................................... 4 2.3.3 TURKEY ...................................................................................................................... 4

2.4 OTHER STUDIES .......................................................................................................... 5 2.4.1 AZERBAIJAN ................................................................................................................ 5 2.4.2 GEORGIA .................................................................................................................... 7 2.4.3 TURKEY .................................................................................................................... 10

3 CHANGES ............................................................................................................. 13

3.1 AZERBAIJAN ............................................................................................................... 13 3.2 GEORGIA .................................................................................................................... 13 3.3 TURKEY ...................................................................................................................... 14 3.4 CROSS-COUNTRY CHANGES .................................................................................. 14 3.5 DESCRIPTION OF ANY MATERIAL AMENDMENT, SUPPLEMENT, REPLACEMENT OR MATERIAL MODIFICATION TO AN ESIA, ESAP, THE RAP, THE ESMS OR ANY OSRP ................................................................................. 14

3.5.1 AZERBAIJAN .............................................................................................................. 14 3.5.2 GEORGIA .................................................................................................................. 14 3.5.3 TURKEY .................................................................................................................... 14

4 COMPLIANCE WITH ENVIRONMENTAL STANDARDS AND APPLICABLE ENVIRONMENTAL LAW .................................................................... 14

4.1 SUMMARY OF ANY NOTICES OF NON-COMPLIANCE, REMEDIAL ACTION, ANY FINES OR PENALTIES PAID AND FINAL DISPOSITION OF ANY REGULATORY PROCEEDINGS ............................................................................ 14


4.2 MONITORING RESULTS ............................................................................................ 15 4.2.1 AZERBAIJAN .............................................................................................................. 15

4.2.1.1 Ambient Air Quality ....................................................................................... 15 4.2.1.2 Stack Emissions ........................................................................................... 15 4.2.1.3 Noise ............................................................................................................ 16 4.2.1.4 Effluent ......................................................................................................... 16 4.2.1.5 Ground and Surface Waters ......................................................................... 16 4.2.1.6 Waste Management ..................................................................................... 17

4.2.2 GEORGIA .................................................................................................................. 17 4.2.2.1 Ambient Air Quality ....................................................................................... 17 4.2.2.2 Stack Emissions ........................................................................................... 17 4.2.2.3 Noise ............................................................................................................ 18 4.2.2.4 Effluent ......................................................................................................... 18 4.2.2.5 Ground and Surface Waters ......................................................................... 18 4.2.2.6 Waste ........................................................................................................... 19 4.2.2.7 Flora and Fauna ........................................................................................... 20

Environmental and Social Annual Report 2009

ii

4.2.3 TURKEY .................................................................................................................... 20 4.2.3.1 Ambient Air Quality ....................................................................................... 20 4.2.3.2 Stack Emissions ........................................................................................... 20 4.2.3.3 Noise ............................................................................................................ 21 4.2.3.4 Aqueous Discharges .................................................................................... 21 4.2.3.5 Groundwater ................................................................................................. 21 4.2.3.6 Waste Management ..................................................................................... 21

4.3 STATEMENT OF COMPLIANCE ................................................................................ 21 4.4 CHANGES IN APPLICABLE ENVIRONMENTAL LAW .............................................. 22

4.4.1 EU LEGISLATION ....................................................................................................... 22 4.5 CHANGE IN NATIONAL LEGISLATION ..................................................................... 22

4.5.1 AZERBAIJANI LAW ..................................................................................................... 22 4.5.2 GEORGIAN LAW ........................................................................................................ 22 4.5.3 TURKISH LAW ........................................................................................................... 23

5 OIL SPILL RESPONSE ......................................................................................... 23

5.1 SUMMARY OF OSRPS COMPLETED, UPDATED, OR AMMENDED DURING THE YEAR ........................................................................................ 23 5.2 SPILL AND REMEDIATION SUMMARIES ................................................................. 23


5.2.3.1 Contained ..................................................................................................... 24 5.2.3.2 Uncontained ................................................................................................. 25 5.2.3.3 Illegal Taps ................................................................................................... 25 5.2.3.4 Remediation ................................................................................................. 25

5.3 SUMMARY OF MATERIAL MODIFICATIONS TO THE OSRPS ................................ 25

6 ADDITIONALITY PROGRAMMING ....................................................................... 26

6.1 SUMMARY OF EIP ...................................................................................................... 26 6.1.1 AZERBAIJAN .............................................................................................................. 26 6.1.2 GEORGIA .................................................................................................................. 26

6.1.2.1 Construction Phase EIP Projects ................................................................. 26 6.1.2.2 Forest Eco-compensation Project ................................................................ 26 6.1.2.3 Operations Phase EIP .................................................................................. 26

6.1.3 TURKEY .................................................................................................................... 28 6.1.3.1 Project Status ............................................................................................... 29

6.1.4 EIP EXPENDITURES, 2009 ........................................................................................ 30 6.1.5 EIP BUDGET, 2010 ................................................................................................... 31

6.2 SUMMARY OF CIP ..................................................................................................... 31 6.2.1 AZERBAIJAN .............................................................................................................. 33 6.2.2 GEORGIA .................................................................................................................. 33 6.2.3 TURKEY .................................................................................................................... 34

6.2.3.1 Summary of the Regional Development Initiative (RDI) Programme ........... 36 6.2.4 CIP EXPENDITURES 2009 ......................................................................................... 37

6.3 CIP BUDGET, 2010 ..................................................................................................... 38

7 E&S MONITORING PROGRAMME ....................................................................... 38

7.1 INTERNAL MONITORING ........................................................................................... 38 7.2 EXTERNAL MONITORING ......................................................................................... 38

7.2.1 HOST GOVERNMENT MONITORING ............................................................................. 38 7.2.1.1 Azerbaijan ..................................................................................................... 38 7.2.1.2 Georgia ......................................................................................................... 38 7.2.1.3 Turkey ........................................................................................................... 39


iii

7.2.2 NGO MONITORING ................................................................................................... 39 7.2.2.1 Azerbaijan ..................................................................................................... 39 7.2.2.2 Georgia ......................................................................................................... 39 7.2.2.3 Turkey ........................................................................................................... 39

7.3 TRAINING .................................................................................................................... 40 7.3.1 AZERBAIJAN .............................................................................................................. 40 7.3.2 GEORGIA .................................................................................................................. 40 7.3.3 TURKEY .................................................................................................................... 40

8 PROJECT COMMUNICATION .............................................................................. 41

8.1 CONSULTATION APPROACH ................................................................................... 41 8.2 AZERBAIJAN ............................................................................................................... 41

8.2.1 PROJECT AFFECTED COMMUNITIES ........................................................................... 41 8.2.1.1 Interim Routine Right of Way Access Strategy ............................................ 41 8.2.1.2 Complaints .................................................................................................... 41

8.2.2 NGOS AND TECHNICAL ORGANISATIONS .................................................................... 42 8.2.3 GOVERNMENT ........................................................................................................... 42

8.3 GEORGIA .................................................................................................................... 42 8.3.1 PROJECT AFFECTED COMMUNITIES ........................................................................... 42

8.3.1.1 Complaints .................................................................................................... 43 8.3.2 NATIONAL NGOS AND TECHNICAL ORGANISATIONS .................................................... 43 8.3.3 GOVERNMENT MINISTRIES AND DEPARTMENTS........................................................... 43 8.3.4 MEDIA ...................................................................................................................... 44 8.3.5 DONOR ORGANISATIONS ........................................................................................... 44

8.4 TURKEY ...................................................................................................................... 44 8.4.1 CONSULTATION ......................................................................................................... 44

8.4.1.1 BIL ................................................................................................................ 44 8.4.1.2 Community Meetings .................................................................................... 45 8.4.1.3 Regional Stakeholders Meetings .................................................................. 46

8.4.2 COMPLAINTS MANAGEMENT ...................................................................................... 46 8.4.3 BTC ......................................................................................................................... 47

8.4.3.1 Consultation Activities with Government, NGOs and Other Donor Institutions ............................................................................................... 47 8.4.3.2 Media ............................................................................................................ 48

9 LAND ACQUISITION AND COMPENSATION ...................................................... 48

9.1 AZERBAIJAN ............................................................................................................... 48 9.1.1 LAND ACQUISITION, EXIT AND COMPENSATION ........................................................... 48 9.1.2 LAND ACQUISITION PROGRAM FOR 6M ACCESS CORRIDOR FOR INTERIM ROUTINE RIGHT OF WAY ACCESS STRATEGY ................................................... 48 9.1.3 AGI CERTIFICATES CHANGE ...................................................................................... 49

9.2 GEORGIA .................................................................................................................... 49 9.2.1 ACQUISITION AND COMPENSATION ............................................................................. 49 9.2.2 LAND REGISTRATION AND OWNERSHIP ....................................................................... 49 9.2.3 RAP FUND ............................................................................................................... 49 9.2.4 LAND HAND-BACK ..................................................................................................... 50

9.3 TURKEY ...................................................................................................................... 50 9.3.1 ACQUISITION AND COMPENSATION ............................................................................. 50 9.3.2 LAND MANAGEMENT DURING OPERATIONS ................................................................. 50 9.3.3 TRANSFER OF LAND RIGHTS ...................................................................................... 51 9.3.4 RAP MONITORING .................................................................................................... 51

9.3.4.1 Internal RAP Monitoring - BNB (formerly RUDF) ......................................... 51 9.3.4.2 Fishermen Monitoring ................................................................................... 51

10 SUMMARY OF KEY HEALTH AND SAFETY STATISTICS .................................. 52

10.1 BTC PROJECT (CONSTRUCTION) H&S PERFORMANCE ...................................... 52 10.2 BTC OPERATIONS H&S PERFORMANCE ............................................................... 53


iv

11 AUDITS ................................................................................................................. 54

11.1 INTERNAL REVIEWS ................................................................................................. 54 11.1.1 AZERBAIJAN .............................................................................................................. 54 11.1.2 GEORGIA .................................................................................................................. 55 11.1.3 TURKEY .................................................................................................................... 56

11.2 EXTERNAL REVIEWS ................................................................................................ 58 11.2.1 ISO 14001 CERTIFICATION ....................................................................................... 58 11.2.2 INDEPENDENT ENVIRONMENTAL CONSULTANTS .......................................................... 58 11.2.3 SOCIAL AND RESETTLEMENT ACTION PLAN (SRAP) PANEL ........................................ 59 11.2.4 AZERBAIJAN SOCIAL REVIEW COMMITTEE .................................................................. 59 11.2.5 POLARIS ................................................................................................................... 60 11.2.6 TURKEY EXTERNAL REVIEWS/AUDITS ........................................................................ 60

APPENDIX 1 .............................................................................................................. 62

APPENDIX 2: ENVIRONMENTAL MONITORING RESULTS ................................... 64

APPENDIX 2.1: AZERBAIJAN .............................................................................................. 64 APPENDIX 2.1A – AMBIENT AIR QUALITY .............................................................................. 64 APPENDIX 2.1B – STACK EMISSIONS MONITORING ................................................................ 65 APPENDIX 2.1C – ENVIRONMENTAL NOISE ............................................................................ 65 APPENDIX 2.1D – EFFLUENT DISCHARGE MONITORING PROGRAMME ..................................... 66 APPENDIX 2.1E – GROUNDWATER & SURFACE WATER MONITORING PROGRAMME ................. 67 APPENDIX 2.1F – WASTE ..................................................................................................... 68

APPENDIX 2.2: GEORGIA ................................................................................................... 69 APPENDIX 2.2A – AMBIENT AIR QUALITY .............................................................................. 69 APPENDIX 2.2B – STACK EMISSIONS .................................................................................... 70 APPENDIX 2.2C – ENVIRONMENTAL NOISE ............................................................................ 71 APPENDIX 2.2D – EFFLUENT ................................................................................................ 75 APPENDIX 2.2E – GROUND AND SURFACE WATERS .............................................................. 77 APPENDIX 2.2F – WASTE ..................................................................................................... 78

APPENDIX 2.3: TURKEY ..................................................................................................... 79 APPENDIX 2.3A – AMBIENT AIR QUALITY .............................................................................. 79 APPENDIX 2.3B – STACK EMISSIONS .................................................................................... 79 APPENDIX 2.3C – AQUEOUS DISCHARGES ............................................................................ 81 APPENDIX 2.3D – WASTE ..................................................................................................... 89

APPENDIX 2.4: GHG EMISSIONS ....................................................................................... 90

APPENDIX 3: CLOSE OUT STATUS OF ACTIONS RELATED TO NON-COMPLIANCES RAISED THROUGH IEC MONITORING .......................... 91

APPENDIX 3A – AZERBAIJAN ACTION STATUS AGAINST AUDIT NON-COMPLIANCES AND RECOMMENDATIONS ................................................................................................. 91 APPENDIX 3B – GEORGIA ACTION STATUS AGAINST AUDIT NON-COMPLIANCES AND RECOMMENDATIONS ................................................................................................. 92 APPENDIX 3C – TURKEY ACTION STATUS AGAINST AUDIT NON-COMPLIANCES AND RECOMMENDATIONS ................................................................................................. 93

APPENDIX 4: STATUS OF RECOMMENDATIONS RAISED THROUGH SRAP MONITORING ............................................................................. 101

APPENDIX 5: FINDINGS AND KEY RECOMMENDATIONS OF POLARIS AUDIT 104

CASE STUDIES CASE STUDY 1: PIPELINES AWAKEN ANCIENT HISTORY IN AZERBAIJAN

CASE STUDY 2: ECO-COMPENSATION IN GEORGIA

CASE STUDY 3: CREATING SUSTAINABLE LIVELIHOOD FOR FISHERMEN COMMUNITIES IN CEYHAN


v

ABBREVIATIONS

ACG - Azeri, Chirag, Gunashli (offshore oil fields)

AGI - Above Ground Installation

APLR - Association for the Protection of Landowners Rights

ASA - Advanced Safety Audit

AzSPU - Azerbaijan Strategic Performance Unit

bbl - Barrel

BIL - Botaş International Ltd

BNB - See RUDF

BOD - Biochemical Oxygen Demand

BOSS - Behavioural Observation Safety System

BTC - Baku-Tbilisi-Ceyhan Pipeline

BTEX - Benzene, Toluene, Ethyl Benzene and Xylene

CARE - CARE International NGO

CAS - Centre for Archaeological Studies, Georgia

CBG - Caucasian Black Grouse

CBO - Community Base Organization

CCIC - Consolidated Contractors International Company

CDAP - Caspian Development Advisory Panel

CDI - Community Development Initiative

CIP - Community Investment Programme

CLO - Community Liaison Officer

CMAS - Competency Management and Assessment System

CMT - Ceyhan Marine Terminal

CO2 - Carbon dioxide

COD - Chemical Oxygen Demand

COPE - Conflict Prevention through Environmental Awareness for Youth

CTU - Crude Topping Unit

CWAA - Central Waste Accumulation Area

DAFWC(F) - Days Away From Work Cases (Frequency)

dB - Decibel

DRC - Development Resource Centre

DSA - Designated State Authority (Turkey)

E&S - Environmental and Social

EBRD - European Bank of Reconstruction and Development

EDDF - Emergency Drain Down Facility

EHC - Environmental Health Criteria

EIA - Environmental Impact Assessment

EIP - Environmental Investment Programme

EMS - Environmental Management System

ERM - Consulting Company Environmental Resource Management Ltd

ESA - Ecologically Sensitive Area

ESAP - Environmental and Social Action Plan

ESD - Emergency Shutdown

ESER - Environmental and Social Evaluation Report


vi

ESIA - Environmental and Social Impact Assessment

EU - European Union

FCI - Facilities Construction and Installation

GEF - Global Environmental Facility

GIOC - Georgian International Oil Company

GIS - Geographical Information System

GHG - Greenhouse Gas

GTZ - Deutsche Gesellschaft fur Technische Zusammerarbeit (NGO)

HGA - Host Government Agreement

H&S - Health and Safety

H1 - First half of year (January – June)

H2 - Second half of year (July – December)

HGA - Host Government Agreement

HiPo(f) - High Potential Incident (frequency)

HIV - Human Immunodeficiency Virus

HSE - Health, Safety and Environment

HSSE - Health, Safety, Social and Environment

IBA - Important Bird Area

IBC - International Blue Crescent

IEC - Lenders’ Independent Environmental Consultant

IFC - International Finance Corporation

IFI - International Finance Institution

IGA - Inter Government Agreement

IMC - International Medical Corps

IMS - Incident Management System

IoAE - Azerbaijan Institute of Archaeology and Ethnography

IoB - Azerbaijan Institute of Botany

IP - Implementing Partners

IPA - Important Plant Area

IPLOCA - International Pipeline and Offshore Contractors Association

IPT - Intermediate Pigging Station (Turkey)

ISO - International Standards Organisation

ISP - Improved Schools Project

IUCN - International Union for Conservation of Nature and Natural Resources

KP - Kilometre Point

KPI - Key Performance Indicator

LLC - Limited Liability Company

LP - Low pressure

MENR - Ministry of Ecology and Natural Resources (of Azerbaijan)

MOC - Management of Change

MoE - Ministry of Environment (Georgia)

MOL - Main Oil Line

NACRES - Noah’s Ark Centre for Recovery of Endangered Species (NGO)

NDVI - Normalised Difference Vegetation Index

NGO - Non-Governmental Organisation

NOx - Nitrogen Oxides


vii

OSI - Open Society Institute (Azerbaijan)

OSR - Oil Spill Response

OSRB- - Oil Spill Response Base

OSRP - Oil Spill Response Plan

PAC - Provisional Acceptance

PM - Particulate Matter

PSA - Pump Station, Azerbaijan

PSG - Pump Station, Georgia

PT - Pump Station, Turkey

PTW - Permit to Work

Q1/Q2/Q3/Q4 - Quarter 1 / Quarter 2 / Quarter 3 / Quarter 4

QIP - Quick Impact Project

RAP - Resettlement Action Plan

RBC - Rotating Biological Contactor

RDI - Regional Development Initiative

RINJ - Recordable Injuries

ROW - Right of Way

RUDF - Rural and Urban Development Foundation (now called BNB)

SARMS - Special Area Reinstatement Method Statement

SCP - South Caucasus Pipeline

SES - Seacor Environmental Services

SESMeke - Joint Venture between SES and Meke Marine

SIF - Small Investments Fund

SLAP - Supplementary Land Acquisition Programme

SLCC - State Land and Cartography Committee

SME - Small and Medium Enterprises

SO2 - Sulphur Dioxide

SOC - Safety Observation and Conversation

SoLoNOX - Solar Turbines Dry Low Emissions Technology

SPJV - Spie Petrofac Joint Venture

SPPD - State Pipeline Protection Department (Georgia)

SRAP - Social and Resettlement Action Plan

SSPS - Special State Protection Services (Azerbaijan)

STP - Sewage Treatment Plant

TOC - Total Organic Compound

TPH - Total Petroleum Hydrocarbons

TVA(R) - Traffic Vehicle Accident (Rate)

UN - United Nations

UNDP - United Nations Development Programme

VOC - Volatile Organic Compound

VPI - Vulnerable People Initiative

WBH - Water Bath Heater

WHO - World Health Organisation

WWTP - Waste Water Treatment Plant


1

EXECUTIVE SUMMARY

BTC Co. (hereinafter BTC) and its agents have complied in the development, construction and operation of the BTC Project with the Environmental and Social Action Plan (ESAP), applicable environmental laws and applicable Lender Environmental Policies and Guidelines in all material respects during the period covered by this report.

There was one governmental fine incurred against BTC in Georgia during 2009 for the late submission of an environmental report. With this exception there were no other fines or penalties incurred for environmental or social non-compliances, and no material environmental claims against BTC during 2009.

There was one Class III change submitted to Lenders for approval. This related to the temporary use of municipal waste water treatment facilities in Azerbaijan for the disposal of raw sewage and sewage sludge. There were no ESIA addenda submitted.

During the year there were four oil spills, all minor, and no significant heath and safety incidents.

A number of HSE audits and reviews took place during the year.

The 11th post-financial audit of the Independent Environmental Consultant (IEC), acting on behalf of BTC Lenders took place in June. One new non-compliance was raised, (lack of back-to-back BIL community liaison staff in Turkey Area 3), and one level 1 non-compliance retained (stack emission NOx levels in Azerbaijan and Georgia). Previous issues with non-hazardous waste disposal were closed following the start-up of the BP Georgia EU-compliant non-hazardous waste landfill.

An internal Safety and Operational Integrity Audit across Azerbaijan and Georgia found no legal non-compliances. The majority of its recommendations (72%) were closed by the end of the year.

In May BTC in Azerbaijan and Georgia were audited by Moody International against the environmental management system standard ISO 14001. There were no system non-compliances and BTC retained its ISO14001 certification.

An Oil Spill Response readiness assurance review for Azerbaijan and Georgia conducted by Polaris concluded that BTC had maintained and improved its oil spill readiness capability since the 2007 review.

The RAP Completion Audit quantitative and qualitative surveys that began in 2008 were completed. The final audit report is awaited from the SRAP auditors.

Emissions monitoring for the operations phase continued and results were generally in compliance. Monitoring of gas turbine exhaust gases showed some exceedences of NOx levels, believed to be due to the turbines operating at low load conditions. There were a number of cases where monitoring of aqueous effluents indicated that some parameters exceeded project standards. In such cases the effluent was not discharged to the environment but was taken to a treatment plant for final disposal.

In Turkey the contaminated soil (approx. 4,000m3) arising from the BVT30 incident in 2008 was removed to the Izaydas landfill. Final site clearance and demobilisation was achieved by the 12th of December.

Environmental and community investment programmes totalling $5.6 million for the year continued to benefit communities along the pipeline route.


2

1 INTRODUCTION

2009 was the fourth year of operating the BTC pipeline. On the 18th December a new milestone was reached when the 1,000th tanker, the British Kestrel, was loaded at Ceyhan. By the end of the year over 803 million barrels of oil had been exported by BTC since the first tanker was loaded at Ceyhan on 4th June 2006.

This BTC Annual Environmental and Social (E&S) Report has been prepared and structured in accordance with the requirements of Annex J of the ESAP governing construction of BTC and Annex H of the ESAP governing the operations phase of BTC. These requirements are reproduced in Appendix 1. It is the sixth Annual E&S Report post-financing and covers the calendar year 20091.

2 ESIAs / EIA AND PERMITTING

2.1 SUMMARY OF ANY MATERIAL MODIFICATIONS TO THE ESIAS2

There were no material modifications made to the BTC ESIAs in Azerbaijan, Georgia and Turkey in 2009.

2.2 SUMMARY OF MATERIAL PERMITS ISSUED IN 2009

2.2.1 Azerbaijan

In 2009 an approval for the drilling of sub-artesian water well at the BTC PSA 2 Camp facilities in Yevlakh was obtained from the Ministry of Ecology and Natural Resources of Azerbaijan.

2.2.2 Georgia

A summary of Statutory Environmental Permits acquired by BTC Georgia in 2009 is as follows:

Tree felling consent issued by Borjomi Municipality Council for Tori secondary containment facility (SCF).

Mineral Extraction License for a water well at the Emergency Drain Down Facility (EDDF).

2.2.3 Turkey

During 2009 the following activities took place with respect to material permits in Turkey:

Non-Hygienic Establishments Operation Permits applications for permanent permits for Adana, Erzincan, Erzurum, Sivas, Ardahan and Kahramanmaras provinces remained unchanged in 2009. Permits can only be obtained after the approval of air emission permits. The process is ongoing for the air emission permits for these provinces. As the related regulation changed in 2009, the application is going to be renewed and submitted in 2010.

An application for a ‘shore facilities operating licence’ was made in 2009. The process is ongoing and it is expected that the licence will be granted in 2010.

1 While construction started in 2003-Q2, the financing for the project was finalised in early 2004-Q1.

2 Environmental and Social Impact Assessment. Note that in Turkey the formal terminology is EIA (Environmental

Impact Assessment).


3

An Emergency Response Plan related to law 5312 (Response to Emergencies and Compensation of Losses in case of Pollution of the Marine Environment by Oil and Other Harmful Substances) was submitted to the MoEF in 2008. The process is ongoing.

A Discharge Permit application was made for the new waste water treatment plant built at IPT1 in December 2009. The process is ongoing.

2.3 UPDATE ON STATUS OF PROJECT SPECIFIC REQUIREMENTS FOR FURTHER WORK UNDER THE ESIAS OR PERMITS

A summary of country-specific activities relating to ongoing studies or surveys as required under the ESIAs or permits is given below. Studies or surveys noted as completed in the 2008 Annual report are not shown.

2.3.1 Azerbaijan

The only ‘Additional ESIA Study and Survey’ as specified in the Operations ESAP relates to a groundwater monitoring programme.

Study/Survey: Groundwater Monitoring Programme

Expected Timing: Monitor water level and quality: Ongoing

Ref: 2004-Q1 (p5-3); 2004-Q2 (p3-3); 2004-Q3 (p3-2); 2004-Q4 (p3-2); 2005-Q1 (p3-2);

2005-Q2 (p3-2); 2005-Q3 (p3-2); 2005-Q4 (p3-1), 2006-H1 (p3-1), 2007 (p4); 2008 (p4)

Groundwater monitoring was carried out according to the ESAP requirements in May 2009 and November 2009. A summary of results is given in Section 4.2.1.5 and the data sheets are presented in Appendix 2.

Completion Status: ONGOING

In the Construction ESAP there was a requirement to translocate Iris acutiloba off the ROW prior to construction. This requirement was fulfilled, and monitoring of the success of the relocation was ongoing in 2009. Similarly, Cultural Heritage programme Phase V (Analysis and Reporting) was ongoing during 2009. A summary of the results of both these surveys are given below:

Study/Survey: Iris acutiloba Monitoring Programme

Expected Timing: Monitoring: Ongoing

Ref: 2004-Q1 (p5-2); 2004-Q2 (p3-2); 2004-Q3 (p3-1); 2004-Q4 (p3-2); 2005-Q1 (p3-1);

2005-Q2 (p3-2); 2005-Q3 (p3-1); 2005-Q4 (p3-1), 2006-H1 (p3-1), 2007 (p5); 2008 (p4)

Following two surveys in 2007 to assess Iris acutiloba survival rates, a further detailed field survey was carried out during March–April 2008 and 2009 (the Iris acutiloba growing season). In total 6,127 individuals (19% of all bulbs transplanted) were successfully located using GPS and observed to be viable (either sprouting and visible above the ground, or alive but comprising only a dormant bulb beneath the soil surface). Of these, 3,286 individuals (38.7% of those originally transplanted there) were observed off-ROW and 1018 individuals were observed on-ROW (4% of those originally transplanted there) in 2009.

Because it is extremely difficult to locate the dormant bulbs beneath the ground surface when relying on the GPS system (+/-1 metre accuracy), it is preferable to gather data on the numbers of sprouting irises. It is not uncommon for natural (non-commercial) bulbs of this kind to remain dormant after transplantation for 3 or more years before sprouting. Given this, it is considered to be too soon to be able to make an informed judgement regarding the success of this programme. Further surveys shall be conducted during the 2010 and subsequent growing seasons, after which a more meaningful determination will be possible.



4

Study/Survey: Cultural Heritage – Archaeology Phase V (Analysis and Reporting)

Expected Timing: Phase V: Ongoing

Ref: 2004-Q3 (p3-2); 2004-Q4 (p3-2); 2005-Q1 (p3-2), 2005-Q2 (p3-2); 2005-Q3 (p3-2);

2005-Q4 (p3-1); 2006-H1 (p3-1), 2007 (p5); 2008 (p5)

A new archaeology exhibition "Pipelines awaken ancient history" was opened in April 2009 to display objects discovered on the route of the BTC and SCP pipelines. This permanent exhibition is located in the Caspian Energy Centre (CEC). It was developed by the designer and curator of the Smithsonian Institution in collaboration with the Azerbaijan Institute of Archaeology and Ethnography (IOAE). The exhibition introduces the lifestyle of ancient people who lived on the territory of Azerbaijan to visitors of the CEC. IOAE has kindly lent 10 artefacts discovered on the BTC and SCP route to be on display in the CEC along with a historical photo timeline, an animated video, and an interactive touch screen game.


2.3.2 Georgia

Study/Survey: Kodiana Special Projects and Other Legacy Projects

Expected Timing: Monitoring: Projects / Operations

Ref: 2006-H1 (p3-2); 2007 (p-6); 2008 (p-5)

Landscaping of the EDDF is finished. In addition, biorestoration and relocation of translocated species has been completed at Kodiana project area. Survivability rates are planned to be assessed in 2010-Q2. Biorestoration of Kodiana access road (KPs 181-183) is underway (80% completed) and planned to be finished by 2010-Q2. Survivability monitoring and compensative planting will be carried out in accordance with the planned maintenance schedule. The status of other activities is as follows:

Construction of Non-hazardous Sanitary Landfill and BTCX 1&2 completed in 2009-Q2; Construction of OSRB at PSG1 was completed in 2009-Q4. Minor punch list clearance is ongoing. Landscaping commitments associated with the EDDF have been implemented, with the exception of tree planting which will be implemented in 2010-Q2. Construction of the Secondary Containment Structures is complete, while Control buildings will be completed in 2010-Q2. Landscaping for Secondary Containment Structures has been partially fulfilled, and will recommence in 2010-Q2. In addition, relocation of rare species from nursery back to Kodiana sites was implemented at the end of 2009-Q2. The status of other activities is as follows: Installation of sewage treatment plants at PSG2 and Tsalka OSRB is completed (100%). Modification of Retention Ponds is expected to be completed in 2010-Q3. Construction of Area 80 permanent Camp is well ongoing, with completion planned for the end of 2010-Q4. Meanwhile, additions to PSG2 Accommodation Camp is planned to commence at the end of 2010-Q2 while installation of STPs at PSG1 is planned to commence at the beginning of 2010-Q2. Modification of PSG1 and PSG2 Oily Water Separator and Potable Water Treatment Projects design work is due to commence 2010-Q2.


2.3.3 Turkey

Study/Survey: Landscape Plans and Monitoring for Facilities

Expected Timing: Construction and Operations

Ref: 2005-Q1 (p3-4); 2005-Q2 (p3-4); 2005-Q3 (p3-4); 2005-Q4 (p3-4); 2006 Annual (p6) ; 2007 Annual

(p7); 2008 Annual (p16)

An amendment to the CMT landscaping plan was required to accommodate construction of the BTC Co patrol road. The implementation of the plan amendment was conducted by BTC Co. contractor under the supervision of the Landscaping Supervisor. The CMT landscaping plan was revised accordingly.

The status of landscaping that was implemented at all facilities by BTC Co. and handed over to BIL in late 2008 is being monitored during the ad hoc site visits and annual compliance audits. In parallel, BIL’s ROW Monitoring and Maintenance and site teams monitor the condition of landscaping and take necessary action when required.

Completion Status: MONITORING ONGOING


5

Study/Survey: Marine Turtle Survey

Expected Timing: Operations

Ref: 2004-Q1 (p5-10); 2004-Q2 (p3-8); 2004-Q3 (p3-6); 2004-Q4 (p3-5); 2005-Q1 (p3-5); 2005-Q2 (p3-

6); 2005-Q3 (p3-6); 2005-Q4 (p3-5); 2006-H1 (p3-4); 2006 Annual (p7-8); 2007 (p7); 2008 (p16)

The annual marine turtle survey was conducted in June-September 2009. As was the case for previous surveys, the survey was carried out at Sugozu, Akkum, Botaş and Hollanda beaches. In 2009, a total of 163 Chelonia mydas (Green Turtle) nests and 4 Caretta caretta

(Loggerhead Turtle) nest were found in the study area.

A summary of the number of nests observed this year compared with previous years is as follows:

2002 2003 2004 2005 2006 2007 2008 2009

Green Turtle 42 44 213 29 198 57 160 163

Loggerhead Turtle 18 3 3 7 0 1 1 4

The number of Green Turtle nests observed in 2009 is approximately equal to that of 2008 while the number of Loggerhead nests is too small to draw any firm conclusions regarding trends, particularly given that past experience has shown that year-to-year fluctuations can occur.

As with previous surveys, hatchling success was quite high and predator profile was similar to previous years. Generally, neither any significant death of the hatchlings due to scorching effect of the sun nor any significant disorientation (i.e. disorientation due to light sources at night) was determined along the studied beaches.

A summary of the hatchling success observed this year compared to previous years is as follows:

Beaches 2007 2008 2009

Sugozu 80.9 % 87.2 % 76.5 %

Akkum 84.5 % 86.6 % 77.1 %

Botaş 44.4 % 60.7 % 83.9 %

Hollanda 44.4 % 77.0 % 80.5 %

Overall 82.3 % 82.9 % 77.8 %


2.4 OTHER STUDIES

2.4.1 Azerbaijan

Study/Survey: Vegetation Cover & Species Diversity: April / May 2009


In 2009, biorestoration monitoring included species diversity and vegetation cover assessments. The results of the third year of the biorestoration monitoring programme can be summarised as follows:

Vegetation cover data indicates that over a third of transects located in disturbed areas have equal or greater vegetation cover than adjacent, undisturbed areas, and half of the transects have vegetation cover that is no less than 10% lower than undisturbed areas.

On average, all of the habitats exhibit an increasing trend in vegetation cover. However, there are large differences between habitats in the rate and scale of increase.

Species-commonality between the ROW and adjacent, undisturbed areas is still low (mostly around 30%, although some are much lower), and in most habitats there is only a small increase in the commonality recorded between 2007 and 2009.

In general the vegetation recovery on the ROW is following the pattern that would be expected: vegetation cover establishes relatively quickly as species colonise the ROW, but this mostly comprises ruderal species that are not characteristic of the adjacent, undisturbed vegetation.

Analysis of frequency data for selected species shows that, in general, there is an increase in characteristic perennial species, and a decrease in ruderal species on the ROW. Vegetation recovery in the Gobustan region is severely limited. This is probably largely due to the


6

environmental conditions, in particular hydrologic function and soil stability, but disturbance from vehicles and livestock also plays a part.

Transects in the Sangachal area have lower vegetation cover than those further west in Gobustan.

Highly saline soils are prone to very poor vegetation recovery, and in some instances there is no difference in species-composition or vegetation cover since the first year of survey in 2007.


Study/Survey: BTC/SCP Biorestoration (Seeding)


The short to medium term objective of the biorestoration programme is to establish sufficient vegetation cover to meet or exceed the requirements of Erosion Class 3. The longer term objective is to create stable landform conditions that in turn are conducive to the re-establishment of the of original mix of plant species.

To assist this natural process ephemeral and perennial provenance seeds have been collected and broadcasted on the ROW in selected areas (e.g., environmentally sensitive areas (ESA) and areas prone to erosion.

Approximately 550 kg of perennial and 200 kg of ephemeral seeds were collected during the summer and autumn collection periods. These seeds will be broadcast in key areas in spring 2010.


Study/Survey: BTC/SCP 6m running track reinstatement


One of the key commitments of the BTC Environmental and Social Impact Assessment (ESIA) and the Resettlement Action Plan (RAP) is to ensure that areas disturbed during construction are returned their pre-disturbed conditions.

Since this commitment was made, a Government of Azerbaijan Decree (2003) resulted in the formation of the EPPD (Export Pipelines Protection Department). The EPPD provides security for the WREP, BTC and SCP pipelines in Azerbaijan. It is a state military organisation and is not controlled by BP.

Since 2005 EPPD has patrolled the BTC and SCP ROW by vehicle on a 24 hour basis. These activities have the effect of compacting soils and encouraging the creation of running tracks along the pipeline ROWs. Both outcomes effectively prevent BTC from fulfilling many of its reinstatement and bio-restoration commitments.

Accordingly BTC has had extensive discussions with the EPPD with the objective of reducing patrol traffic on the ROW and thus minimizing impacts. As a result of these discussions it was agreed that, at several locations, EPPD would use alternative roads for routine patrolling and these sections would be reinstated by BTC. This work commenced in November 2009 and has resulted in the reinstatement of 4.5 km of the running track in Gobustan and Shamkir districts. BTC is planning to reinstate another 26 km of running track in Gobustan, Shamkir and Tovuz districts in March, 2010.


Study/Survey: Landscape Monitoring of FCI-ROW


BTC committed to undertake landscape monitoring along FCI-ROW. The programme and corresponding methodology aims to record changes to landscape over time in order to either demonstrate progress in restoring the landscape, or areas where additional intervention is necessary.

Monitoring commenced at 90 vantage points in 2005 and continues annually. In 2009 monitoring was also carried out at all AGIs.

The vantage points were selected to represent a cross-section of landscapes and features and include: rivers and streams crossings; slopes and gullies liable to erosion; areas with high visibility to communities; borrow pits; permanent AGIs, and BVs/CVs; temporary AGIs’ areas; and road crossings within environmentally or socially sensitive areas. Areas that have been fully restored will be removed from the monitoring programme at the end of 2010.



7

2.4.2 Georgia

There were eight ‘Other’ studies/surveys carried out in Georgia in 2009:

Study/Survey: Biodiversity Monitoring off FCI-ROW

Expected Timing: 2009

Progress: BTC committed to undertake a five-year programme for Biodiversity monitoring at off FCI-ROW locations. The programme consists of faunal (including ichthyofauna) and floral (including habitat) components and aims to identify any potential impact caused by pipeline construction and operational activities. It was launched in Spring 2004 and was completed in 2009. Results of the 2009 monitoring as well as cumulative trends are discussed in detail in the Annual Biodiversity Monitoring report, completed in 2009-Q4. As per a 2007 agreement with the MoE of Georgia, BTC conducted biannual invasive species surveys across BTC/SCP ROW in 2009. Remedial actions were implemented where necessary, e.g., a locally registered herbicide was used to treat a site heavily infested with Ambrosia. Ichthyological surveys undertaken in 2009 ended the five year annual monitoring programme. During this period river and stream crossings were visited and assessed using a range of metrics including a river assessment algorithm (assigning scores to selected environmental indices based on invertebrate field survey data) and an Index of Biotic Integrity (IBI) pursuant to EPA standards, Various metrics were also developed and measured for periphyton, water quality and fish productivity and the results used to develop a 3-year trend analysis for all rivers and streams. The cumulative trend-based values can be used as a background for future operational impacts related activities.

Completion Status: COMPLETED

Study/Survey: Landscape Monitoring of FCI-ROW


Progress: BTC committed to undertake landscape monitoring along FCI-ROW. The objective of the programme was to systematically record visual changes at predetermined locations and therefore measure progress in restoring the landscape. The programme is based on a monitoring methodology that was revised in 2007 to ensure consistency with the requirements of the ESAP. As in previous years the following features have been included in the scope: river and stream crossings; bear crossings; slopes and gullies liable to erosion; seismic faults; areas with high visibility to communities; borrow pits; permanent AGIs, including PSGs and Block Valves; temporary AGIs’ areas; road crossings within environmentally andsocially sensitive areas; and rare species reintroduction locations. Data has been incorporated into GIS.


Study/Survey: Vegetation Cover Recovery and Potential Erosion Risk Assessment within BTC & SCP Right-of-Way (ROW), 2009


Progress: Vegetation cover regrowth trends and erosion risk potential are being monitored annually. The main findings of the vegetation cover analysis and erosion risk assessment within BTC & SCP ROW based on the data collected over the three years of observation (2007-2009) are summarised below. All habitats

3(based on 100m long ROW sections):

Vegetation cover within the ROW approximates to that of the adjacent undisturbed areas for the majority of the pipeline corridor. A decrease in cover occurred in 12.4% of the 100m ROW sections between 2008 and 2007; 14% between 2009 and 2008 and 7.8% between 2009 and 2007. Overall an increase in cover has occurred in 92.8% of the 100m ROW sections between 2009 and 2007.

In 2007 8.5 ha of disturbed areas (representing all habitats) had vegetation cover in the range 0-10%; in 2008 vegetation cover of 0-10% was observed in 12.3 ha while in 2009 the area of such sections reaches almost 16 ha. Even though total area with <10% vegetation cover has increased since 2007, the total area of the ROW sections with vegetation cover of 90-100% has increased from 4ha in 2007 to 10ha in 2008 and almost 12ha in 2009.

3 excluding agricultural land.


8

Erosion Potential Assessment Using GIS-Based USLE Erosion potential assessment was conducted based on the methodology detailed in the report “Vegetation Cover Recovery Trend & Potential Erosion Performance Analyses by Satellite Imagery” produced by BTC Co. Desktop USLE evaluation shows that, in 2009, 94.7% of the ROW meets the biorestoration target achieving Erosion Class 3 or better. Areas assessed as being Erosion Class 4 or greater have been identified at 30 locations and are subject to follow up by field crews. The species diversity surveys covered 49 sample points or transects selected at random (applying sample generator software developed specifically for this project) among all the defined habitat types occurring along the pipeline corridor. The results of the 2009 survey indicate that approximately 41% (294) species are found only within the ROW or off the ROW (i.e., not both), which is slightly lower than in 2007 (54% or 314 species). This indicates a tendency for convergence between floras on and off the ROW. Conversely, approximately 8% (52) species occur both on and off the ROW. This is higher than in 2007 (6% or 36 species) which again suggests convergence. Detailed information can be found in the Species Diversity 2009 report. The next round of Vegetation Cover and Erosion potential assessment monitoring is scheduled to commence in April 2010.


Study/Survey: Botanical Survey of South Georgian Wetlands (Second year)

Expected Timing: 2007-2009

Progress: An agreement was reached between BTC and the MoE of Georgia to mitigate pipeline construction related impacts in wetland areas within the BTC/SCP ROW. Botanical surveys of wetlands will be conducted in southern Georgia with the aim of identifying a high conservation value site worthy of protection status under the Ministry for Protection of Environment and Natural Resources of Georgia. Accordingly, field studies of 15 wetland sites on Javakheti Upland (South Georgia) were carried out in June-September 2008 and July 2009. In total, 246 plant taxa (59 mosses, 187 vascular plants) and 29 different plant communities were recorded in 202 sample plots. In summary this survey is the first comprehensive study of mid- to high altitude wetlands in Georgia and therefore represents a significant contribution to the knowledge of wetland communities in the Caucasus. Based on the survey results, six sites are proposed for designation of protection status. These sites are Levangyol, Godorebi-Didi Abuli, Abulgyol, Avchalagyol, Agrikari-Emlikli and Madathapa Lake. Examination of floristic quality showed that nutrient-poor fen meadows (Didi Samsari, Satchem, Gorelovka and Kirkh-Bulagi) support richer flora with higher number of rare and endemic species.


Study/Survey: Bat Mitigation Pilot Project

Expected Timing: 2008-2009

Progress: The 2003 pre-clearance surveys identified a total of 134 trees with hollows - potential shelters for the Chiroptera located within the ROW or adjacent Tetritskaro and Borjomi administrative districts (47 and 87 respectively). All these trees were destroyed as part of the ROW clearance. It was therefore proposed to install artificial bat shelters in the forested areas adjacent to the ROW to mitigate this loss. A pilot project involved installation of fifty artificial bat shelters in the vicinity of BTC/SCP pipeline ROW in Tetritskaro administrative district (KPs 88 and 91). Six different models of shelters were provided in order to accommodate different species and different number of individuals. While the first-year activities of the Bat Mitigation Pilot Project are described in detail in the Bat Mitigation Pilot Project Summary Report, 2008, 2009 fieldwork involved two activities: (1) monitoring rates of colonization, and (2) shelter cleanup. The 2009 surveys showed that three shelters were stolen, three were found to be occupied by bats, while remainder were either empty or inhabited by various animals including insects (butterflies, wasps, bees and spiders), various birds and mice.



9

Study/Survey: Rare floral species management programme


Progress: The main objective of the rare species monitoring programme was to measure the survival rates of the translocated species against the objective of re-establishing a minimum of 75% of the original population within the areas designated for translocation. This commitment has been achieved in nine species out of eleven; no individuals of Gentiana angulosa (two populations) and Orchis coriophora were recorded on the reintroduction sites.

Fifteen populations of eleven rare herbaceous species reintroduced to the ROW and its close vicinity were assessed in spring-summer 2009 in order to evaluate reintroduction success. A set of biotic and abiotic characteristics were recorded for each population and a fertility and vitality index was calculated to evaluate the sustainability of the populations. Low index values (<50%) were calculated for two populations of Gentiana angulosa and Galanthus alpinus var. alpinus, and for single populations of Pulsatilla georgica, Scilla rosenii and Orchis coriophora. Grazing and trampling, together with relatively slow adaptation to undisturbed habitats, are the most likely explanations for the low index values.

Surveys to assess survivability rates will continue to be undertaken twice during 2010. The survey methodology is described in Operations procedure “Evaluation of Reintroduction/ Adaptation Success of Rare Species” (AZSPU-HSSE-DOC-00185-3).

Formalized results are available in the 2009 monitoring report.


Study/Survey: Survey of invasive common ragweed Ambrosia artemisiifolia and Reed Canary-Grass Digraphys arundinacea and in the vicinity of the BTC/SCP ROW


Progress: A survey of the BTC/SCP ROW conducted in Georgia in 2009 revealed the presence of 8 populations of alien species on the ROW. Two of these – Ambrosia artemisiifolia and Robinia psedoacacia – are invasive taxa with effective dispersal mechanisms (Ambrosia artemisiifolia has been studied separately to elaborate effective control measures).

Results of the survey are summarized in a separate report “Mechanical and Chemical Control Options for Invasive Common Ragweed Ambrosia artemisiifolia Recorded in the BTC/SCP ROW”). A high proportion of observed alien species are naturalized annuals and are likely to be gradually replaced with native perennials.


Study/Survey: Assessment of trees and shrubs survival


Progress: A total of 68,819 trees and 14,265 shrubs have been planted along the ROW by BTC since the end of construction. Ten randomly selected planted sections were surveyed in 2009 to determine tree and shrub survival rates.

The survey revealed that of those surveyed, 2,991 trees and 1,024 shrubs survived. This is equivalent to a mean survival rate of 4.3% for trees and 7.1% for shrubs. These results are considerably less than the established performance target of 75% survival. The major factors affecting the low success of planting were water deficiency, grazing/trampling, weed impact, poor soil conditions and vandalism (removal of saplings and stakes by third parties). Unusually low temperatures during the spring vegetative period, together with frosts, strong winds and insufficient snow cover may have affected the saplings planted in some sites at higher altitudes.

The findings of surveys conducted in 2008 and 2009 clearly indicate that survival expectations need to be tempered to account for local environmental circumstances and interventions by third parties, as well as the fact that regular and ongoing maintenance may have little affect on the overall outcome. These have led to the consideration to the forest eco-compensation programme (refer to Case Study on Forest Eco Compensation project).

Expanded recommendations are given in the survey report “Assessment of Trees and Shrubs Survival Georgia”, AGT Project, 2009.



10

Study/Survey: Erosion filed survey


Progress: In September, 2009 BTC and SCP companies undertook erosion field surveys along some sections of the pipeline ROW between KPs 176 - 220 to determine erosion potential. These sections were identified as sites with high erosion potential based on the modeling (GIS-based USLE assessments). The key objective of the field surveys was to ground truth erosion potential of these sites and assess and document their current status in terms of erosion.

The sites identified were located in three main zones: (1) KP 176 - KP 177 (Tskhratskaro), (2) KP 192 - KP 200 (Kodiana), and (3) KP 218 - KP 220 (Sakuneti - Minadze).

In order to evaluate erosion class of the selected ROW sections, detailed visual surveys were conducted along the entire length and width of each section; in addition, adjacent areas were also inspected for comparison. Qualitative-quantitative assessment of vegetation cover and surface composition was based on visual assessment and expert judgment.

In total, 36 sites were surveyed. None was assessed as having an erosion potential that exceeded the first three classes (i.e., 1- Very Slight; 2 - Slight; 3 - Moderate).

Site-specific recommendations are given in the Erosion Field Survey Selected Sections of the ROW, 2009 report.


Study/Survey: Biorestoration works along BTC/SCP ROW: Kodiana access road (KP181-183)


Progress: The impact of the GB18 access road on the adjacent forest and its consequences on drainage patterns and growth of native species was assessed. In addition a forest restoration plan involving the planting of trees and shrubs was implemented in accordance with a landscaping plan. Four species were planted: Scots Pine (Pinus sylvestris), Oriental Beech (Fagus orientalis), Black Alder (Alnus barbata) and Goat Willow (Salix caprea). Planting will be completed in 2010. A maintenance plan will also be implemented. Site-specific recommendations are given in the work completion report on landscaping at the Kodiana access road.


Study/Survey: Landscaping works around PSG2


Progress: To comply with BTC ESIA commitment No Y12 (Physical Presence of AGIs - A landscaping plan will be implemented which will use grass, shrubs and trees, where practicable, to screen the AGIs and associated access roads. Screening will be subject to ongoing monitoring.) BTC Co decided to undertake measures to mitigate natural habitat deterioration and visual intrusion.

Planting activities therefore took place around PSG2 in autumn, as vegetation starts late in the mountains. Maintenance works are prescribed and planned for 2010.

Site-specific recommendations are given in the 2009 completion report.


2.4.3 Turkey

Ten other studies were carried out in 2009 in Turkey. Details are as follows:

Study/Survey:

Tree and Shrub Survival Monitoring


Ref: 2007 Annual (p10-11); 2008 Annual (p21)

An MOC prepared in 2009 proposed that the original tree and shrub planting programme described in the ESIA be replaced with an off-set planting programme for areas where long-term protection, aftercare and ownership could be assured.

Planting was initiated by MoEF in 2009 and will be completed in 2010. Maintenance will be MoEF’s responsibility. BTC Co. will ask for progress updates from MoEF, but otherwise will not be involved in any further monitoring.



11

Study/Survey: Ceyhan Sediment Quality Survey


Ref: 2006 Annual (p9-10); 2007 Annual (p11); 2008 Annual (p21)

The annual CMT sediment quality and marine ecology surveys were conducted in August 2009. Below are the outcomes of the surveys:

Sediment Quality:

Sediment samples were collected from 12 different locations near the BTC Jetty and analyzed for nine trace metals (Cu, Sn, Zn, Cd, Pb, Hg, Al, Fe, Cr).

In general, there was an overall decline in concentrations of metals between 2004 and 2009, although Cu, Cr, Hg and Fe increased at some locations with annual fluctuations

Cr, Zn, Pb, Cu, Cd, Al and Hg were distributed to the east of BTC Jetty in Iskenderun Gulf whilst Sn was distributed to the west suggesting that Sn possibly has a land origin. Sn, Fe concentrations at all stations, and Cu and Cr concentrations at some, were above the international guideline values. The high Fe, Cu and Cr concentrations might be attributed to the industrial facilities (such as iron-steel, fertilizer factories) at the east of Iskenderun Gulf. All metal distributions showed that the area was polluted, with the high concentrations, indicating long term anthropogenic inputs.

Concentrations for Hg, Cd, Pb and Zn in all of the sediment samples are below the established international and national guideline values and other literature values.

Total Petroleum Hydrocarbon (TPH) (C5-C10 and C10-C28 components) concentrations measured in sediment samples collected around the jetty were lower than the guideline values reported for Class A sites (100 mg/kg) and Class B sites

4. Thus, it was concluded

that there was no significant TPH contamination in the area.

Marine Ecology:

No significant differences were observed in relation to water parameters (nutrients, dissolved oxygen, chlorophyll-a, secchi disc depth, pH, turbidity, conductivity, temperature, density) over the period 2001, 2005, 2007 and 2009. All samples were within acceptable limits, as compared with reference values.

No significant increase in nutrient concentrations was observed in the study area

No sign of Zostera marina was observed during the survey period, which is consistent with

the results of previous surveys.

In general, the structure of the phytoplankton community appears normal, as was the species composition of zooplankton in the vicinity of the BTC jetty. Finally the ichthyoplankton species composition and abundance of the area sampled was similar to that recorded in July 2008.

Despite the unproductive sea bottom, most of the commercially important fish and prawn species typically of the region inhabit the survey area.


Study/Survey: Waste Water Feasibility Survey


Ref: 2007 Annual (p12); 2008 Annual (p22)

In Q1, all facilities were visited to identify options that would enable wastewater systems to meet project compliance requirements.

Construction activities have since begun at the PT1 and PT3 WWTPs and are scheduled for completion in 2010. BIL and BTC Co. will continue to work collectively on the justification and timing of other elements of the environmental enhancements.

Previously approved enhancement items (e.g., IPT1 WWTP installation and commissioning of a settling tank for the WWTP at CMT) were finalized in 2009. An application for a discharge permit was made to Provincial Directorate of MoEF in December 2009. The granting of permit will be followed up in 2010.


4 CCME Canadian Soil Quality Guidelines of Environment Canada (March, 1997).


12

Study/Survey: Ballast Water Management Study


Ref: 2007 Annual (p10-11); 2008 Annual (p22)

Two different Ballast Water Risk Assessment (BWRA) studies were undertaken for CMT by Tubitak MAM in order to help calculate the relative overall risk of introducing a harmful alien species to İskenderun Bay. The first BWRA covered the period between 4

th June 2006 and

28th May 2007 and including 54 source ports. The second covered a 2 year period, between

4th June 2006 and 2

nd November 2008 and included 102 source ports.

A general comparison of 2007 and 2008 BWRA studies is presented in the table below.

BWRA Assess-ment

period

No. of visit

record

No. of source

port

No. of source port in the following risk categories:

highest high medium low lowest

First study (2007)

12 months

164 54 6 8 10 11 19

Second study (2008)

29 months

573 102 13 16 18 22 33

Tubitak MAM also undertook an environmental similarity analysis. This enables BIL to assess risks associated with a previously un-assessed source port to be assessed prior to the ship arriving at CMT so that ballast water management can be applied pro-actively.

The BWRA will be updated in 2010.


Study/Survey: Coastal Processes Survey

Ref: 2007 Annual (p13); 2008 Annual (p23)

The coastal processes survey was carried out between December 2009 and January 2010. The report is in preparation. The results will be summarised in the 2010 Annual Report.


Study/Survey:

Right of Way (ROW) Physical Monitoring


Ref: n/a

Physical monitoring of the ROW is conducted on a yearly basis. Three monitoring programmes have been completed to date; in 2007 (May and June), 2008 (May and June) and 2009 (June and July).

The scope includes an assessment of erosion, landscape restoration, oil contamination and ROW access with a particular focus on priority areas such as archaeological sites, river crossings, ESAs, illegal tap locations as well as side and steep slopes.

A total of 37 archaeological sites were inspected. All were found to be in good condition. The same conclusion was made for the ESAs.

Erosion was the common issue identified in all three monitoring programmes. Class 1-2 erosion was evident in three of the ESAs (ESA 4, 8 and 37) and was consistent with the results of the survey conducted in the previous year. In addition the 2009 survey identified an enhanced erosion risk in three additional ESAs (ESA 1, 24 and 35).

Seventy five river crossing were inspected in 2009. Erosion (in about 50% of the locations visited) and deformed rip-rap, represented ongoing concerns.

Eighteen illegal tap locations were visited in 2009. In general, these sites were assessed as being in a safe condition; no signs of oil contamination were identified since 2008.

During 2009 monitoring programme 236 slope locations were inspected. Around 50% of the monitored slopes were found to have remained in good state since the previous monitoring campaigns. For the remaining 50%, erosion was a prevailing concern.



13

Study/Survey:

CMT VOC Speciation Analysis


Ref: n/a

Speciation analysis for the Volatile Organic Compound (VOC) stacks at CMT was carried out to identify the VOC standards that apply to enclosed ground flare (EGF) emissions and to confirm if any continuous emissions monitoring (CEM) is legally required for EGF. The study results confirmed that the mass flow rate of emissions was below the regulatory threshold to justify a CEM. The report that will be used to identify which HC emission standard set applies to VOC emissions will be completed in 2010-Q2.


Study/Survey:

Waste Management Best Practicable Option (BPEO) Study


Ref: n/a

A Best Practicable Environmental Option (BPEO) for the management of solid wastes arising from BTC operations in Turkey was initiated and an implementation plan was developed for 2009 and 2010.

Following the pre-screening phase, the study identified five municipal landfill sites (to be used for domestic waste disposal) and four cement factories (to be used for hazardous waste disposal) located along the pipeline route. (N.B. Izaydas is being used for disposal of domestic and hazardous waste generated from BTC Turkey facilities). The study focused on the facilities which had the potential to accommodate project wastes in accordance with Project standards (including the EU standards). The study is ongoing; the complete report will be finalized in 2010.


3 CHANGES

As reported in previous Annual Reports, the BTC Project uses a management system process called “Management of Change” (MOC). Proposed changes with potential associated environmental or social impacts are graded by three Classes – I, II or III, as defined in the ESAP. Class III changes are the most significant. Changes are subject to a process of review and approval by BTC, including review and approval by the Lenders for Class III changes. Class I and II changes do not require direct approval by the Lenders, but are assessed as part of the in-country monitoring process by the Lenders’ Independent Environmental Consultant. The following sections summarise BTC approved changes as recorded during 2009.

3.1 AZERBAIJAN

There was one Class III change in Azerbaijan in 2009.

Asset Class Approved Internally

Description of Change

BTC/ SCP Az

III May 2009 Sewage disposal

Disposal of raw sewage and sewage sludge to external municipal wastewater treatment facility.

This MOC covers temporary use of external wastewater treatment facility for treatment and disposal of sewage water in emergency situations and sewage sludge disposal.

3.2 GEORGIA

There were no changes made in Georgia in 2009 with potential associated environmental impacts.


14

3.3 TURKEY

There was one Class II change in Turkey related to reforestation that was internally approved in July 2009. The purpose of MOC was to address reinstatement commitments and the anthropogenic threats to reforestation and hence to identify the most practical and appropriate locations where the reforestation should be applied for the number of felled trees which could not be replanted in the same location from which they were removed.

3.4 CROSS-COUNTRY CHANGES

There were no cross-country Class I, II and III changes in 2009.

3.5 DESCRIPTION OF ANY MATERIAL AMENDMENT, SUPPLEMENT, REPLACEMENT OR MATERIAL MODIFICATION TO AN ESIA, ESAP, THE RAP, THE ESMS OR ANY OSRP

3.5.1 Azerbaijan

No material amendments to the Azerbaijan BTC ESIA or RAP were made in 2009.

Development of the BTC ESMS continued and in October 2009 the system was externally audited by Moody International and re-certified to ISO14001 standard.

The Azerbaijan Oil Spill Response Plan was updated and amended as described in Section 5.3.

3.5.2 Georgia

No material amendments to the Georgian BTC ESIA, ESAP or RAP were made in 2009.

Execution of two material modifications to the BP operations (BTC expansion and non-hazardous landfill) led to an expansion of BTC ESMS. In 2009 the system was externally audited by Moody International and re-certified to ISO 14001 standard.

3.5.3 Turkey

There were no material changes to the Turkey BTC EIA, ESAP or RAP other than those described in Section 3.3.

4 COMPLIANCE WITH ENVIRONMENTAL STANDARDS AND APPLICABLE ENVIRONMENTAL LAW

4.1 SUMMARY OF ANY NOTICES OF NON-COMPLIANCE, REMEDIAL ACTION, ANY FINES OR PENALTIES PAID AND FINAL DISPOSITION OF ANY REGULATORY PROCEEDINGS

All notices of non-compliance served by the IEC in 2009 are detailed in Appendix 3 of this report.

4.1.1 Azerbaijan

There was one Level I non compliance incurred by IEC in Azerbaijan relating to stack emissions (for not relocating generators sample ports and for adjustment of NOx standards).


15

There were no government fines or penalties incurred for environmental or social non-compliances, and no material environmental claims were made against BTC in Azerbaijan during 2009.

4.1.2 Georgia

There was one Level I non compliance incurred by IEC in Georgia relating to stack emissions (for not relocating generators sample ports and for adjustment of NOx standards).

There was one government fine incurred for environmental non-compliances against BTC in Georgia during 2009 for late submission of an environmental report as per a mineral extraction license from the Environmental Protection Inspectorate of the Ministry of Environmental Protection and Natural Resources.

4.1.3 Turkey

There was one Level I non compliance in Turkey relating to public and community relations activities.

There were no government fines or penalties incurred for environmental or social non-compliances, and no material environmental claims were made against BTC in Turkey during 2009.

4.2 MONITORING RESULTS

During 2009 environmental monitoring of the operation of the BTC Pipeline continued in accordance with the BTC Emissions Management Plans. These plans were developed to ensure compliance with project standards as well as to monitor, minimise and where necessary mitigate the environmental impact of pipeline operations.

4.2.1 Azerbaijan

4.2.1.1 Ambient Air Quality

Annual ambient air quality monitoring was carried out at PSA2 six times and covered the period from January to December 2009. Sampling devices were deployed for four weeks at five locations around PSA2 station and PSA2 Camp. Analyses were carried out for NO2, SO2, and benzene.

Monitoring at IPA1 was conducted in September, 2009. Analyses were carried out for NO2 and SO2.

In accordance with the ESAP, annual average concentrations need to be calculated at each monitoring point for each parameter. All results indicated compliance with the ESIA specified limits, although at the PSA2 Reed Beds elevated concentrations of SO2 were detected (30 µg/m3 in Sep-Oct, compared with a project standard of 20µg/m3). The investigation showed there was road construction around PSA2 Camp and the main entrance was temporary closed. All vehicles used to use the detour road which was next to the Reed Beds. The vehicle emissions could have been the reason for the temporarily elevated levels of SO2.

A summary of monitoring results is provided in Appendix 2.1a.

4.2.1.2 Stack Emissions

Stack emissions monitoring was carried out for all major combustion plants at BTC Pipeline Stations: (PSA-2 - 3 Main Power Generators, 4 Turbines and WBH, IPA-1 - 2 Main Power Generators). All of the stacks were sampled for NOx, CO, SO2, and PM10. This successfully concludes all of the stack emissions monitoring required by the ESAP within one year of full start-up.


16

The monitoring results of all BTC diesel generators (PSA-2 Generators A, B, C; IPA-1 Generators A, B) and Water Bath Heater indicated that the oxides of nitrogen (NOx), carbon monoxide (CO), sulphur dioxide (SO2) and particulate matter (PM) concentrations were well below the limits specified for these plants in the BTC Azerbaijan ESIA (AzSPU-HSSE-PMT-00571-A1) and ESAP Emissions Management Plan (AZSPU-HSSE-PMT-01265-2).

However monitoring results of the BTC PSA-2 MOL Turbines indicated that the oxides of nitrogen (NOx) concentrations were higher than the 75 mg/m3 limit specified in the BTC ESAP (AZSPU-HSSE-PMT-01265-2) for this plant, but lower than the 125 mg/m3 limit specified in the BTC Azerbaijan ESIA (AzSPU-HSSE-PMT-00571-A1). Taking into account that the emission standard set in the ESAP was based on the LCPD (which is currently not applicable to turbines of this size) and the inconsistency between limits specified in the BTC ESIA it is proposed to replace the limits to UK, Environmental Protection Act5 standard for BTC Azerbaijan PSA-2 MOL turbines. A MOC is currently under discussion with the IEC.

A summary of monitoring results is provided in Appendix 2.1b.

4.2.1.3 Noise

In 2009 environmental noise monitoring took place in accordance with ESAP requirements at two pre-identified receptors around PSA2, at three pre-identified receptors around IPA1, and at 6 BTC Block Valves which are located less than 300m from community receptors.

All of the results at all locations indicate compliance with the standards in the ESAP.

A summary of monitoring results is provided in Appendix 2.1c.

4.2.1.4 Effluent

BTC’s effluent discharges in 2009 comprised treated sewage from PSA2 and PSA2 Camp.

Sewage from PSA2 and PSA2 Camp undergoes three stages of treatment: (i) biological treatment, (ii) UV sterilisation, and (iii) final polishing in reed beds. This system in PSA2 Camp was successfully commissioned and the final treated effluent has been continuously discharged from the reed beds to a nearby drainage canal from March onwards. Discharges to the environment were in full compliance with the ESAP standards at all times for five out of the six parameters, namely pH, TSS, COD, ammonia, total nitrogen.

There were two instances when the treated sewage discharge was temporarily out of compliance with regard to Coliform bacteria (August and September). On these occasions the Coliform bacteria ranged from 552/100ml to 1234/100ml compared with the standard of 400/100ml. No adverse environmental impact was detected in the receiving water. In both cases the cause of these exceedences (a defective UV lamp and excessive flow) was investigated and corrective actions taken.

Commissioning of IPA1 RBC was started in the end of December 2009.

A summary of monitoring results is provided in Appendix 2.1d.

4.2.1.5 Ground and Surface Waters

In 2009 surface and groundwater monitoring was carried out in May and in November. Groundwater samples were taken from five monitoring wells at the Karayazi aquifer (because two wells were dry and one well had been vandalised) and from two wells at PSA2. Surface water samples from five locations around IPA1 and PSA2 were taken in May and in November.

5 Environmental Protection Act 1990, Part I Secretary of State's Guidance Gas Turbines, 20-50 MW Net Rated Thermal

Input.


17

All the results indicated no significant deterioration from pre-project baseline conditions.

A summary of monitoring results is provided in Appendix 2.1e.

4.2.1.6 Waste Management

During 2009 waste management practices were maintained and improvements undertaken to minimize waste generation through awareness sessions, tool-box talks etc. All wastes were handled and disposed of in accordance with BP AzSPU waste management requirements.

A summary of waste generated is provided in Appendix 2.1f.

4.2.2 Georgia


There were seven rounds of monitoring conducted in 2009 (February, April-May, June, July, August, October, and December) at PSG 1 and PSG 2. The February round of monitoring was conducted as part of the programme. The 2009 programme started in April.

As required by the ESAP monitoring was conducted in April within the month of highest results from previous year.

Measurements were taken at five locations around PSG 1 and PSG 2 for NO2, SO2, and benzene. All results demonstrated compliance with the relevant standards.

A summary of monitoring results for Ambient Air Quality is provided in Appendix A2.2.1.

A summary of GHG air emissions calculations results is provided in Appendix A2.2.6.


Stack emissions monitoring was carried out for NOx and CO. The monitoring results for generators demonstrated full compliance with the specified standards.

The annual round of the stack emissions monitoring for MOL Turbines took place in March 20106. All of the stacks were sampled for NOx, CO, SOx and calculations for PM10 were performed. In addition, CO2 was monitored at the request of Operations.

The monitoring results for the MOL turbines demonstrated compliance with all parameters with the exception of NOx. Although the turbines are fitted with low emission technology (hence emissions are well below those of conventional turbines) this only becomes fully active when the turbine speed exceeds 97% of its design maximum. As the turbines operate below this point for much of the time it impossible always to meet the low NOx emission limit that was initially specified in the ESAP. The turbines only run in low NOx mode during higher temperatures when the efficiency of the turbines reduces, so they must rotate faster in order to provide the required power.

One-off monitoring took place during Solonox mode at MOL Turbine No2, demonstrating full compliance with all the parameters of ESAP.

The monitoring results for WBHs demonstrated full compliance with ESAP standards.

CTUs were activated on a quarterly basis and PSG 1 CTU was used in January 2010 and PSG 2 CTU in February 2010. The next activation round is planned for 2010-Q2 as well as the CTU stack emissions monitoring.

A full set of results is given in Appendix A2.2.2. 6 Due to the need for the stack emissions monitoring instrument Testo to be used for the duration of 2009, it had been

sent for calibration and maintenance later than usually and not returned until the end of the year.


18

4.2.2.3 Noise

In 2009 environmental noise monitoring took place on quarterly basis around PSG 1 (including Area 72) and PSG 1 camp, PSG 2 and PSG 2 camp, Area 80 and Akhaltsikhe camp, Tsalka and Borjomi OSRBs. In Q4, the EDDF was added to the list of monitoring locations.

All of the results at all locations indicate compliance with the ESAP project specified standards.

A summary of monitoring results for environmental noise is provided in the Appendix A2.2.3.

4.2.2.4 Effluent

BTC’s effluent discharges in 2009 comprised treated sewage from PSG 1, PSG 1 camp, PSG 2, PSG 2 camp and Akhaltsikhe camp. All of these discharges are subject to regular monitoring.

The results indicate general compliance with the project specified standards with the following exceptions:

PSG 1 –seven out of twelve TSS and six out of twelve Coliform bacteria;

PSG 1 camp – three out of twelve Coliform bacteria;

PSG 2 – one out of eight TSS and two out of eight Coliform bacteria;

PSG 2 camp – five out of twelve Coliform bacteria.

A summary of monitoring results is provided in Appendix A2.2.4.

The reason for the elevated TSS and Coliform bacteria was revealed during investigations conducted in 2008 (and reported in the 2008 BTC Annual Report). As a result of these investigations a maintenance programme was set up for the retention ponds at the pump stations and the STPs at the camps.

The programme also included replacement of the effluent pumps and concreting the bases of the retention ponds. In addition, it was agreed that new Kee Process RBC units would replace the original STPs located at PSG 1 camp (with the capability to treat effluent from PSG 1 pump station), PSG 2 pump station, and the Tsalka OSRB. It was also agreed that the existing RBC would be maintained at Borjomi OSRB.

To date new RBCs have been installed at the Tsalka OSRB and the PSG 1 site. Each is now being commissioned. In addition the STP at the new EDDF has been installed and is being commissioned.

The programme is scheduled to be completed by the end of 2011.

4.2.2.5 Ground and Surface Waters

In April 2009 BP and Government of Georgia reached a significant agreement in relation to ground water and surface water monitoring baseline data (Ref: BTC/OUT/1755; BTC/OUT/1904; BTC/OUT/1905). In this agreement the frequency of ground water and surface water monitoring will be kept at two seasonal rounds per annum. The following parameters will be monitored: BTEX, Naphthalene from PAH and TPH.

GoG also accepted the baseline data set for 101 of a total of 112 monitoring locations; the 11 exceptions were: BMW 9, BMW 10, BMW 11, TMW 7, TMW 13, TMW 15, TSW 9, TSW 20, KTMW 4, KTMW 14 and KTMW 15.


19

It was agreed that the 11 locations would be monitored on monthly basis in 2009, beginning from first seasonal round of monitoring, and that BP and GOGC/MoE would discuss the monitoring results to agree baseline data that will be used as reference limits for all future monitoring rounds. Two full seasonal rounds (May-June and September-October) and two additional rounds, as per agreement with GoG (July and August), were conducted at 6 locations in 2009. The remaining 5 locations will be monitored in 2010.

The results for the first round of monitoring demonstrated elevated levels of benzene at 8 out of 120 locations. The rinsate of used bottles also showed an elevated level of benzene, which suggested cross contamination of samples from long stored sample bottles.

New sample bottles were subsequently requested from the laboratory and the next rounds of monitoring demonstrated full compliance with the recommended trigger levels for all parameters of interest.

The dry well rehabilitation programme was completed in 2009. Historically dry wells were (re)drilled and/or washed and re-included on the list of monitoring locations.

Water supply re-sampling was also been completed for the seven specific locations as requested by the MoE.

A summary of groundwater and surface water monitoring results is provided in Appendix A2.2.5.

4.2.2.6 Waste

A summary of waste generated in 2009 is given in Appendix 2.2A. The main waste generation areas are at PSG1 and PSG2. The Central Waste Accumulation Area (CWAA) continues to be utilised by Operations for the management of hazardous waste that cannot be recycled or disposed of in accordance with appropriate standards.

In 2009 the project started using a waste processing and recycling centre (WPRC) for operational non hazardous wastes. All non hazardous waste generated from BTC/SCP and WREP sites are collected at this centre for secondary and final segregation. Recycling waste (plastic bottles, paper and cardboard) is stored in special containers. Activities include sorting for reuse, secondary recycling, storage and separation. Non-recyclable waste is sent to landfill for final disposal on monthly basis. An operations-phase WPRC is located at Sanitary Base in Rustavi.

In 2009 BP Georgia continued using local PET manufacturer Caucasus PET Company for recycling of plastic waste. More than 100 tonnes of plastic were delivered for recycling during 2009. In addition “”Vargi LTD” recycled 191.2 m3 of paper/cardboard and 29m3 of metal waste was sent to “NSM & Company”.

Various waste plans were approved during 2009. These were: Waste Management Plan (WMP); Waste Management Implementation Plan (WMIP); Waste Offset Plan (WOP) and; Waste Projects Plan (WPP). These plans outline particular actions to improve waste management, to develop a new non-hazardous landfill, to close the Level 3 non-compliance associated with the BTC Iagluja waste disposal site, and to set offset mechanisms for compensation of past non-compliant waste disposal.

In May 2009 the first EU-standard non hazardous waste landfill in Georgia commenced operations. By the end of 2009 the landfill had received 2700 m3 of waste.

BP continued using food waste macerators and a dewatering system at PSG1 Camp, PSG2 Camp and Akhaltsikhe Camp and in so-doing was able to reduce the volume of food waste by 70-80%. Macerated and dewatered food waste was then sent to the WPRC for composting. Composted food waste is used for various purposes e.g. conditioning of ROW, final covering for the landfill, and by local farmers.


20

4.2.2.7 Flora and Fauna

A detailed botanical assessment of the populations of high conservation value species, sensitive habitats and invasive/alien species along the BTC/SCP route was conducted in 2009 by local specialists and international experts. The overall goal of the Floral Component of the Biodiversity Monitoring Programme was to identify and quantify any off-ROW floral impacts of pipeline construction and operation, and recommend any remedial mitigation measures if required. Comprehensive quantitative and qualitative data has been collected in 143 permanent plots, of which 58 were established to monitor forest communities, 36 wetlands, 32 meadows, 2 scrub and 15 populations of species of high conservation value. In addition to these activities, a walkover survey was conducted along the BTC/SCP ROW to identify the presence of populations of invasive/alien species which might pose a threat to local biodiversity. A comprehensive set of data is presented in the 2009 floral component report.

The faunal component of the biodiversity monitoring program covers selected species of amphibians, reptiles, avifauna and mammals and the evaluation of the selected aquatic habitat quality through indicator species (dragonfly guilds).

Six-year trend analysis indicates that the livelihood fluctuations of the nominated faunal species are not related to the pipeline operation activities.

A comprehensive set of data is presented in the faunal component report of year 2009.

4.2.3 Turkey


Ambient air quality monitoring is undertaken only at the Ceyhan Marine Terminal (CMT). The results are presented in Appendix A.2.3. No ambient air monitoring is required at the Pump Stations (PTs) as the major sources of emissions (pump drivers and water heaters) use natural gas as a fuel.

Passive diffuser tubes were used to monitor air quality. VOCs (benzene, toluene, ethyl benzene and xylene–BTEX), SO2 and NOx are measured at 10 locations at and around CMT once in every three months.

In 2009, 4 surveys were undertaken between January and December (although the January 2009 survey actually commenced in December 2008).

The annual average values of all parameters were generally lower than or close to the annual average values of 2007 and 2008 monitoring campaigns as well as the associated baseline values.

The only exceptions were:

The average value of SO2 at CMT3 was high due to the contribution of the quarterly average value in autumn 2009. This is thought to be due to nearby farming activities such as burning of stubble.

Elevated levels of BTEX at CMT1 and CMT10 in winter and spring.


The flue gases originating from gas fired reciprocating engines, water heaters, diesel fired generators and wax handling boilers were monitored by DOKAY in accordance with ESAP EEMP.

Stack emissions monitoring results for 2009 are shown in Appendix A.2.3. The results demonstrate compliance at all facilities.

Stack sampling ports were installed to heaters at all facility camp sites in 2009-Q3. One round of monitoring consistent with the Regulation on Control of Air Pollution Originated from Heating (RCAPOH) has been scheduled for 2010 by BIL.


21

4.2.3.3 Noise

The project standard for noise specifies a maximum of 45 dBA for night time ambient noise levels at sensitive receptors or a 3dBA increase above background levels. Noise modelling was undertaken as part of the ESIA process (Volume II, Section 7.9.4) and indicated that 40dBA is reached a maximum of 50m from the perimeter fence at each pump station. The closest residential receptor to any of the facilities is 1.5 km. Monitoring at off-site residential receptors is therefore not considered necessary unless in response to concerns raised by residents or if there is evidence that on-site noise is rising. Neither of these situations arose during 2009, consequently, no ambient monitoring was conducted.

4.2.3.4 Aqueous Discharges

Aqueous discharges originating from project facilities, as well as downstream surface water bodies which receive the aqueous discharges are monitored on a monthly basis. Upstream water bodies are similarly monitored to establish ‘control’ conditions. Aqueous discharge monitoring results for 2009 are shown in Appendix A.2.3.

The monitoring results showed that no non-compliant discharges were released to environment. However a number of aqueous discharge streams did not meet project standards. For example monthly effluent monitoring results show that there were 25 non-compliant samples among 100 samples taken from the Oily Water Separators (OWSs); 32 non-compliant samples of WWTP effluent among 72 samples and 46 non-compliant samples of Storm Water Pond (SWP) effluent among 60 samples. In such cases the effluent was re-cycled or trucked to Project approved Municipal WWTPs for further treatment.

The recommendations raised from waste water and OWS feasibility surveys which were finalized in 2008, formed part of the 2009 enhancement programme. The details of these studies are provided in Section 2.4.3 of this report.

4.2.3.5 Groundwater

Groundwater quality monitoring programme for operations was developed by BIL in order to monitor:

1. The operational impacts of groundwater abstraction from the wells;

2. The possible contamination by BTC facilities on groundwater;

3. Saline intrusion at the CMT well.

Groundwater level (static and dynamic) will also be monitored on a monthly basis in order to assure that the safe yield is abstracted from the aquifer.

It is anticipated that the programme will commence in 2010.

4.2.3.6 Waste Management

In 2009, about 435 tonnes of solid waste was disposed off-site. Of this, 2.5% was hazardous waste that was sent to Izaydas for incineration, 39% was domestic waste sent to Izaydas for landfill and the rest, 58%, was non-hazardous waste that was re-used or re-cycled.

Appendix A.2.3 provides details of waste volumes generated.

4.3 STATEMENT OF COMPLIANCE

BTC and its agents have complied with the ESAP, applicable environmental laws and Applicable Lender Environmental and Social Policies and Guidelines in all material respects during the period covered by this report.

All non-compliances that have been identified in 2009 are summarized in Executive Summary and shown in Appendix 2. Non-compliances relating to other audits are given in Section 11 (and detailed in Appendices 3 and 4). For all non-compliances identified, corrective actions have been developed and implemented.


22

4.4 CHANGES IN APPLICABLE ENVIRONMENTAL LAW7

4.4.1 EU Legislation

New and amended EU directives, regulations, and decisions announced in 2009 have been reviewed. Potential implications arising from the review are being taken into account as part of the HSSE Compliance Programme. The following Directives have been identified as being potentially relevant to BTC’s legal obligations and, where reasonably practicable, aspects of these will be incorporated into BTC’s HSSE compliance programme (unless otherwise stated):

1. Directive 2009/30/EC dated 23 Apr 2009 amending Directive 98/70/EC as regards the specification of petrol, diesel and gas-oil and introducing a mechanism to monitor and reduce greenhouse gas emissions and amending Council Directive 1999/32/EC as regards the specification of fuel used by inland waterway vessels and repealing Directive 93/12/EEC. This Directive sets technical specifications on health and environmental grounds for fuels to be used with positive ignition and compression-ignition engines, taking account of the technical requirements of those engines and a target for the reduction of life cycle greenhouse gas emissions.

2. Directive 2000/60/EC dated 31 July 2009 on technical specifications for chemical analysis and monitoring of water status. It provides technical specifications for chemical analysis and monitoring of water status and establishes minimum performance criteria for methods of analysis to be applied by Member States when monitoring water status, sediment and biota, as well as rules for demonstrating the quality of analytical results of the limit of quantification concerned for the calculation of mean values.

4.5 CHANGE IN NATIONAL LEGISLATION

The following summary of changes in national legislation of Azerbaijan, Georgia and Turkey aims to give an overview of new legislation and highlight recent developments. Although some may have direct relevance to BTC, inclusion of specific legislation into this Report does not imply its applicability to BTC.

4.5.1 Azerbaijani Law

There were no environmental related legislative changes in 2009 that were potentially relevant to BTC Azerbaijan.

4.5.2 Georgian Law

The following environmental related legislative changes occurred in 2009 that were potentially relevant to BTC Georgia:

1. Resolution No. 799 of the Government of Georgia, dated October 30, 2009, on the Auction License Conditions for Issuing Mineral Extraction License.

2. Resolution No. 1054 of the Government of Georgia, dated December 29, 2005, on Approving the Ministry of Environmental Protection and Natural Resources as the Recipient of the Grant in the amount of USD 3,500,000 to the Georgian Government by BTC Co. & SCPC.

3. Order No. 8 of the Ministry of Environmental Protection and Natural Resources, dated March 9, 2009, on Approving Statute on Environmental Impact Assessment.

7 Applicable environmental laws as defined within HGA and IGA


23

4.5.3 Turkish Law

The list of national environmental regulations that were published or re-issued in 2009 is shown below, along with a statement regarding BTC’s likely response:

Official Gazette No

Official Gazette Date

Regulation On: New / Revision

Impact on BTC Turkey Operations?

27190 04.04.2009 Exhaust Gas Emissions Control

New Exhaust gas monitoring and management of BIL and BTC Co. vehicles will be carried out consistent with the regulation.

27214 29.04.2009 Permits and Licenses that need to be obtained as per environmental law

New Following actions consistent with the regulation will be taken by BIL:

- Environmental permits (air emission, aqueous discharge) and licenses for CWAAs will be received. BIL is exempt for noise permit.

- Online application to MoEF using e-signature should be done through environmental management unit or environmental representative or consultant company. There will be one application for all facilities.

- Following online application, a temporary license for 1 year will be granted by MoEF for BIL to incorporate any comments.

5 OIL SPILL RESPONSE

5.1 SUMMARY OF OSRPS COMPLETED, UPDATED, OR AMMENDED DURING THE YEAR

The OSRP for Azerbaijan was amended and updated in February 2009 and the OSRP for Georgia was amended and updated in September 2009, as summarised in Section 5.3.

5.2 SPILL AND REMEDIATION SUMMARIES

BTC reports any material release that reaches the environment (i.e. is uncontained) or that is greater than 1 barrel, even though it maybe contained. Gas releases are always classified as uncontained. All material releases (liquids, gases or solids) are internally reported and investigated. There is no minimum reportable volume for internal release reporting and investigation. A summary of these releases is given in Table 5.1.

Table 5.1: BTC Material Releases in 2009

Asset Liquid Gas

< 1 bbl > 1 bbl

Uncontained Contained Uncontained

BTC Azerbaijan 0 0 0 0

BTC Georgia 1 0 0 0

BTC Turkey 1 2 0 1


24

Further details on the material release shown in Table 5.1 are given in the following sections.

5.2.1 Azerbaijan

There was one third part diesel spill within ROW safety zone. A tractor operator (landowner) lost control on the steep descent of unauthorized road and the tractor rolled over on the central line of the pipeline. As a result of the rollover, approximately 20 l of diesel fuel were spilt within the pipeline safety zone. Contaminated soil was removed from the accident site and disposed of in accordance with the BTC Waste Management Plan.

There were also two minor spills recorded during the year at IPA1. Both of them were contained and therefore not discussed further in this report. None impacted the environment.

5.2.2 Georgia

There was one minor spill recorded at BTC Georgia in 2009. After a period of heavy rain hydrocarbon sheens and smell of diesel and a lubricant oil mixture were detected at several areas within and outside of the PSG 2 Camp. On investigation it was apparent that the heavy rain had raised the groundwater level and washed out hydrocarbons from an area contaminated during the construction phase. It is evident that this latest event occurred despite the measures applied at the time of the original contamination, such as repair of a generator bund and installation of several hydrocarbon collection sumps). Due to the fact that the ground contamination was historical the total amount of spill could not be estimated but was assumed to be less than a barrel.

The following actions were undertaken in response to the incident:

Oil absorbent booms were located within and outside of the area of the camp to prevent further spread of contamination;

The source of contamination was located;

16m3 contaminated soils were removed and sent to a bioremediation cell located at Rustavi, Sanitary Base;

A new drain channel, with natural separation ponds, was constructed outside and along of the camp fence with the view to intercepting any further oily water discharge.

5.2.3 Turkey

5.2.3.1 Contained

There were two contained spills recorded during the reporting period:

Estimated 1 bbl crude oil (PT1 – June 2009)

The spill occurred at PT1 and was caused by a leaking wax handling unit. Oily water was collected in a pit and pumped into the slops system and then re-injected into the pipeline.

Unknown size of spill – taken as > 1bbl (PT2 – June 2009)

The spill occurred when the site team drained the relief tanks during routine maintenance. The water passed through the oily water separator (OWS) and ended up in the primary withholding pond (PWHP) causing a significant colour change (to brown) at the pond.


25

5.2.3.2 Uncontained

There were two uncontained material releases in 2009:

Estimated 0.31 bbls crude oil (BVT 24 – August 2009)

The spill occurred due to a cavity drain pipe connection failure at BVT 24 HV. SESMeke team collected the contaminated soil, and the contaminated waste was transferred to central waste accumulation area of PT3.

Release of Gas (CMT – November 2009)

The release occurred when the Enclosed Ground Flare (EGF) system was down for approximately 12 hours on 16th of November, as a result of excessive vibration at blower roller bearing (Berth 1).

5.2.3.3 Illegal Taps

No illegal tap occurred in 2009.

5.2.3.4 Remediation

A bioremediation programme was developed by BIL for the contaminated soils originating from previous illegal taps. The programme is ongoing with monitoring activities.

BVT30

About 4,000 m3 of contaminated soil was generated as a result of a fire that occurred in August 2008 at BVT30. The contaminated soil was temporarily stored in a lined and bunded area while a detailed review of disposal options was conducted. As a result of the review the contaminated soil was transported to the Izaydas landfill site. The transport activities commenced on the 10th of November 2009 and continued until 9 December 2009. Final site clearance and demobilisation was achieved by the 12th of December 2009.

5.3 SUMMARY OF MATERIAL MODIFICATIONS TO THE OSRPS

The OSRP for Azerbaijan was amended and updated in February and for Georgia, in September of 2009. Section 1.6 Response Planning Guidelines was modified and amended to reflect the changes made to response times under the new Oil Spill Response Tier 2 contract, which came into force in June 2009. As a result of some changes in the structure of the Tier 2 contractor’s (Seacor) personnel, the Distribution list was also amended. Equipment list and contact details were updated and OSR (Tier 3 contractor) Notification and Mobilization forms were revised and modified.

The OSRP for Azerbaijan included the following changes: Section 1.2 was amended to include a section on DRA (Drag Reducing Agent); Section 1.6 Response Planning Guidelines was modified and amended to reflect the changes made to response times under the new Oil Spill Response Tier 2 contract; Section 1.7 Responsibilities for some members of the IMT (Incident Management Team) were amended to reflect the updated IMS (Incident Management System manual); Section 1.9 Public Relations was expanded; Section 2.2 was amended to reflect the changes in the updated IMS; Section 2.1.5 & 3.1 contact details were up-dated; Section 3.4 Scenario was expanded to include a DRA incident and some scenarios were amended to incorporate clean up & remediation strategies and Section 3.5 Forms were revised and modified to incorporate the changes to the OSR (Tier 3 contractor) Notification and Mobilization forms and minor changes were made throughout the OSRP to incorporate the name change of the Tier 3 contractor from OSRL to OSR.


26

6 ADDITIONALITY PROGRAMMING

The BTC Additionality Programmes are carried out through a series of regional and community-based projects. These projects are designed to conserve biodiversity, deliver local and long term benefits, and empower local communities to resolve issues for themselves. The Additionality Programmes were formalised into an Environmental Investment Programme (EIP) and a Community Investment Programme (CIP). CIP and EIP are jointly and equally funded by BTC and SCP in Azerbaijan and Georgia. In Turkey these programmes are 100% funded by BTC.

6.1 SUMMARY OF EIP

6.1.1 Azerbaijan

Since 2009 the Azerbaijan EIP no longer exists as a separate programme but rather within the frameworks of the Sustainable Development Initiative (SDI) and the Community Development Initiative (CDI), see Section 6.2.

6.1.2 Georgia

6.1.2.1 Construction Phase EIP Projects

The Ktsia-Tabatskuri Managed Reserve Management Plan project is jointly funded by both EIP funds and separate offset funds8.

The initial goal of preparing a Management Plan was completed in 2009. The second goal involving capacity building and implementation is currently being conducted by IUCN.

6.1.2.2 Forest Eco-compensation Project

BP Georgia reached an agreement in principle with the government of Georgia on eco-compensations for the forestry loss which occurred during pipeline construction.

Following detailed analysis of options and extensive discussions with Ministry of Environment with the involvement of invited Austrian experts, it was agreed that BP would contribute $3.5 million towards an offset eco-compensational project, namely protection of the Sataplia State Reserve infrastructure development project. The relevant agreement between BP and MoE was signed in January 2010 (See Case Study 2).

6.1.2.3 Operations Phase EIP

The Eco-Awards Program is funded by BP on behalf of BTC and SCP. It rewards individuals and organizations involved in promoting awareness of the environment and its protection. The budget allocated for the program is $ 900,000 for three years (2008-2010). The first transfer of $300,000 was made in December 2008. The following discusses the various programs.

1. Organization: Wild Plant Conservation Association (WPCA)

Project title: Ex-Situ Conservation and Commercial Use of Some Economically Important Species of Wild Flora Protected by CITES Convention

Goal: To support conservation and commercial use of economically important species of wild flora protected by CITES convention.

8 In addition to the Georgia EIP budget of US$3 million, an additional US$1.3 million was designated for Offset

Programmes. To take advantage of synergies with EIP, offset money spent on Ktsia-Tabatskuri Managed Reserve is managed under the EIP.


27

Start/End dates: 25.03.2009 – 24.09.2010

Outcomes: Conducted field visits and collected seeds in Ajara. Seeds were sown in laboratories, greenhouses and in natural conditions outside.

2. Organization: Georgian Tourism Association (GTA)

Project title: Market-Oriented Sustainable Tourism Development in Protected Areas of Georgia

Goal: To facilitate market-oriented, participatory sustainable tourism for the Lagodekhi, Algeti and Kintrishi Protected Areas (PA) in Georgia.

Start/End dates: 23.03.2009 – 22.10.2009 (extended till January 15, 2010)

Outcomes:

Workshops: local products for sustainable tourism in Mtirala national park, Algeti national park, Vashlovani national park.

Video clips: of Kintrishi and Mtirala national parks, Vashlovani national park, Lagodekhi national park. http://www.tourism-association.ge; http://www.youtube.com/user/georgiantourism#p/u)

School camps: in Algeti national park, Vashlovani national park, Lagodekhi national park.

Construction in Algeti national park of picnic area, toilet facility, garbage container, marking of path with signs, road signs, explanatory boards and informational desk.

Printing materials: maps, brochures, photo- documentation, guesthouse booking system (webpage with details and photos).

3. Organization: Biological Farming Association Elkana

Project title: Reviving the Meskhetian Wheat Tsiteli Doli through an Effective Marketing Chain

Goal: To reduce the negative impact of agriculture on the environment in the Samtskhe-Javakheti Region and preserve local agricultural biodiversity by introducing the sustainable use of endemic species.

Start/End dates: 01.06.2009 – 04.02.2011

Outcomes: Organized a ‘Farmers’ Day’ in Akhaltsikhe and completed selection of farmers to participate.

4. Organization: IUCN Programme Office for the Southern Caucasus

Project title: Facilitating Stakeholder Participation in Protected Areas of Georgia

Goal: Promote environment protection in Georgia through facilitating stakeholder participation in Protected Territories.

Start/End dates: 23.03.2009 – 23.11.2010

Outcomes: A strategic framework document was developed to help establish Protected Area Advisory Boards. Stakeholder analysis was carried out, a questionnaire developed and the first charter of Friends Association drafted.

5. Organization: Association for Environment Protection and Sustainable Development “MTA-BARI”

Project title: Support to the cultivation and sale of economically important species of Adjara wild flora in the buffer zone of Mtirala National Park

http://www.tourism-association.ge/

http://www.youtube.com/user/georgiantourism#p/u


28

Goal: To support sustainable use of resources in the buffer zone of Mtirala National Park that envisages sustainable use of economically important and endangered indigenous species of flora and involvement of local population in the marketing development.

Start/End dates: 15.04.2009 – 14.08.2010

Outcomes: 22 families were selected to participate in this programme and a brochure developed containing information on cultivating and marketing economically important species in the region.

6.1.3 Turkey

All ten of the construction phase (EIP 1) projects have been completed, while eight operations phase (EIP 2) projects are ongoing as of the end 2009 (Table 6.1). The eight operations phase projects will continue in 2010 and are described below.

Table 6.1: EIP Turkey: Summary of Activities

Project Phase Started Completed BTC Funds Spent US$

1 Sea Turtle Expedition Construction (EIP 1)

01.08.2003 31.12.2005 175,000

2 Research on Monk Seals Construction (EIP 1)

01.08.2003 31.12.2004 100,000

3 Improving the Conservation and Status of Caucasian Black Grouse in Turkey

Construction (EIP 1)

01.08.2003 31.12.2005 230,000

4 Important Bird Areas in the BTC Pipeline Region


01.08.2003 31.12.2005 215,000

5 Important Plant Areas in the BTC Construction (EIP 1)

01.08.2003 31.12.2005 260,000

6 Lesser Caucuses Forests Gap Analysis


01.02.2004 31.04.2006 305,000

7 Small Investments Fund – Phase 1


01.09.2004 30.04.2007 250,000

8 Awareness Raising Materials on Biodiversity Along the BTC Pipeline


01.11.2004 30.10.2008 200,000

9 Yumurtalik Lagoons Wetland Management Plan and Erzurum Marshes Conservation Zones


01.11.2004 31.12.2007 545,000

10 Participatory Eco-System-Based Planning and Management of Ardahan – Yalnizcam Forests


01.06.2005 30.05.2008 1,110,000

11 Eksisu Wetlands Management Project – Phase 1

Operations (EIP 2)

01.12.2006 On-going 360,000

12 Biogas/Fertilizer Demonstration in Kahraman Maras – Phase 1

Operations (EIP 2)

01.12.2006 On-going 62,000

13 Conservation Priority Analysis for Central and South BTC Region – Phase 1

Operations (EIP 2)

01.12.2006 On-going 1,177,000

14 Grand Kackar Project Operations (EIP 2)

01.12.2006 On-going 50,000

15 Marine Wildlife Rehabilitation Capacity Building

Operations (EIP 2)

01.06.2007 On-going 15,000

16 Small Investments Fund – Phase 2

Operations (EIP 2)

01.05.2007 On-going 420,000

17 Yumurtalik Wetlands Management – Implementation Phase 1

Operations (EIP 2)

01.12.2008 On-going 220,000

18 Conservation of Commercially Important Endangered Endemic Plants in Ardahan and Kahramanmaras

Operations (EIP 2)

01.12.2007 On-going 218,000

TOTAL 5,912,000*

* Two more commitments were about to be made by end of 2009 which total about $ 250,000


29

The original EIP strategy was focussed entirely on the issue of promoting biodiversity. Having met most of the objectives in this area, BTC is considering extending the EIP into other areas where further substantial national benefit would be obtained from capacity building. Three additional areas that have been identified:

National environmental infrastructure (i.e. waste disposal and waste water facilities)

Wildlife Response Capability enhancement in the event of an oil spill

Regulator capacity support (awareness and experience)

6.1.3.1 Project Status

A summary of key EIP developments in 2009 are as follows:

Conservation of Endangered Plants along the BTC Pipeline Region (Phase I):

A pilot garden was allocated and funded by the District Governorship of Cildir, Ardahan with the aim of propagating target species (10,000 plants were planted successfully). A partnership was established with the Cyclamen Society in UK in order to rehabilitate and maintain of the propagation gardens in Baskonus, Kahramanmaras.

Eastern Mediterranean Marine Wildlife Rehabilitation Centre:

Although an extensive set of consultation activities were carried out and key stakeholders such as universities and the Ministry of Environment and Forest (MoEF) were willing to contribute, the full set of elements to ensure sustainability of the Centre was not secured and therefore the project remained in consultation phase in 2009.

Small Investments Fund (SIF-II):

The Small Investment Fund (SIF) is a mini grant programme under EIP. Individual grant projects under SIF were completed in early 2009. Programme level monitoring and documentation was completed in order to assess the impacts of the small grants. Both evaluation and final reports of SIF-II were produced by project partners. Two grant projects were discontinued due to administration issues the grantees faced. The project portfolio included:

1. Development of Ecotourism in Kuyucuk Lake, in Akyaka-Kars

2. Production of Biogas and Biomass from Systematically Collected Cattle Manure, in Hemite-Osmaniye

3. Decreasing the Threats on the Fish Populations in the Rivers of Amanos Mountains, in Dortyol-Hatay

4. Development of Ecotourism in Yogunoluk Village, in Samandag-Hatay: (discontinued)

5. Sustainable and Effective Usage of Resources in the Production of Local Zerun, Kirik and Sigon Organic Wheat, in Pasinler-Erzurum

6. Using Wind Energy for Drinking Water of Kirmitli Municipality, in Kirmitli-Osmaniye: (discontinued)

7. Technical feasibility of use of Modern Fish Barriers in the Yelkoma Lagoons, in Yumurtalik-Adana

8. Bogatepe Village Sustainability and Life with Plants, in Bogatepe-Kars

9. Promoting the Yumurtalik Lagoons for Conservation, in Yumurtalik-Adana: To develop alternative income-generating activities and to establish necessary infrastructure for visitor management


30

Eksisu Marshes; for Nature and People (Phase I):

A Draft Wetland Management Plan was prepared in conjunction with the Erzincan Provincial Directorate of MoEF, Erzincan University and project team. The Draft Plan was later presented to the Local Wetlands Commission. Suggestions were collected from all related stakeholders and incorporated into a revised Management Plan. This document will be sent to the National Wetlands Commission for review in 2010.

Conservation Investment Priority Analysis for the Central and Southern BTC Region:

Priority sites and nature conservation priorities have been identified together with the suggested actions to achieve conservation at these sites. The project team has initiated a long-term consultation process with related state institutions in order to share these proposed actions and establish an implementation plan.

Transferring EIP data into the National Database (Noah’s Ark) was completed except for information collected as part of the Important Plant Areas Project.

The project has also led the General Directorate of Forestry (GDF) to appoint a Chief Engineer of Biodiversity to coordinate all biodiversity studies and to conduct forest biodiversity inventories.

Implementation of the Yumurtalik Lagoons Management Plan (Phase II):

Four projects, all of which are in accordance with the implementation of the Management Plan, were submitted to the Çukurova Development Agency. By June 2009 three of these projects were accepted by the Agency having met the necessary financial criteria.

Other achievements during 2009 included the opening of the Yumurtalik Lagoons Education and Information Centre and the implementation of the Pasture Rehabilitation and Rehabilitation of Yumurtalik Lagoons projects (at a cost of 500,000 TL and 70,000 TL respectively).

A multiple land use agreement involving agricultural and conservation interests in Yumurtalik was also agreed following extensive discussions between local stakeholders and state institutions.

Finally the Yumurtalik Lagoons Management Plan was judged to be the most successful wetland management plan implemented in Turkey during 2009.

Kaçkar Mountains Forest Conservation and Sustainable Rural Development Project:

The project is a continuation of the Lesser Caucasus Forest Gap Analysis and aims to demonstrate ecologically sound community development. The project received a matching fund of $1,800,000 from the EU in late 2006. In 2009 project activities gained momentum with the completion of additional income activities research and non-timber forest products research. Consultation with several local organizations regarding beekeeping lead to a workshop involving approximately 150 local beekeepers and the development of a 2-year work plan.

6.1.4 EIP Expenditures, 2009

Table 6.2 shows the amount budgeted for the EIP and cumulative expenditure since the inception. Table 6.3 shows the breakdown of expenditures for 2009.


31

Table 6.2: EIP Budget and Expenditures ($), 2003-2009

Azerbaijan Georgia Turkey9 TOTAL

EIP Budget 3,467,000 3,000,000 6,550,000 13,017,000

Total Spent to date

(at end 2009) 1,697,298 2,672,948 6,490,000 10,860,246

Table 6.3: Summary of EIP (Operations Phase) Expenditures ($), 2009

Azerbaijan Georgia Turkey TOTAL

Planned 0 300,000 850,000 1,150,000

Actual 0 445,00010

800,000 1,245,000

6.1.5 EIP Budget, 2010

The EIP and CIP budgets in Azerbaijan were consolidated and became part of the overall social investment budget (refer Table 6.5).

Table 6.4 shows the breakdown of 2010 planned budget.

Table 6.4: EIP Budget ($), 2010

Georgia Turkey TOTAL

Budget 2010 750,000 610,000 1,360,000

6.2 SUMMARY OF CIP11

The following table summarises the projects being performed across all three countries under the CIP (Table 6.5). This is followed by an outline of project activity in each country.

9 Includes technical support to grantees on top of the grants awarded.

10 Additional $145K to the initially planned $300K was added in 2009 for Ktsia-Tabatskuri Reserve Management

implementation project 11

In Azerbaijan term Community Investment Program (CIP) has changed to Community Development Initiative (CDI).


32

Table 6.5: BTC/SCP CIP and Other Investments - Visualising the Benefits (up to end 2009)

Investment Type AZERBAIJAN GEORGIA TURKEY

Number of communities benefiting 150 77 326

Amount of money invested (US$) $12.96 million12

$4.08 million $18.7 million ($ 2.3 m was allocated for 2009)

Implementing Partners (IP)/ Number of local/national NGOs

5 IPs and 11 local NGOs 1 IP and 5 NGOs assisting

4 IPs (all national) and 66 local NGOs (association, Coop. farmer union) assisting

% Women in Community Action Groups

— 22% Varies from 8% to 40% according to region. (All CIPs have separate projects targeting 100 % women)

Number of medical facilities improved 42 2 11

Number of education facilities improved

52 (in addition 14 schools have received computers)

5 133 schools upgraded (in addition 622 women/girls applied to open school programme)

Number of water supply systems improved

98 (potable and irrigation) 24 potable, 19 irrigation 123 potable water systems including 12 electrical motor pump system improved, 14 irrigation system improved

Km of road upgraded 274.42 km 10 km Road improvements were not included in CIP Turkey (In 2009 only 4 km field road in Erzurum and 3 km pasture road in Ardahan). Construction

Contractors upgraded the roads.

% Infrastructure project achieving >25% community contribution

— 100% 95% All infrastructure projects have cash or in-kind beneficiary’s contribution. 29 projects finished in 2009 and 382 from beginnings.

Number of medical staff trained 497 0 401

Number of people receiving direct medical support

183,970 0 34,840 people received general health trainings (also over 13,000 people received Reproductive Health training from an

EU funded project implemented by a CIP IP in Ardahan)

Number of micro loans issued 423,84413

4,138 (Except Geben association micro-loans were cancelled and funds are used for collective income generation activities in agro-businesses by

cooperatives 30 micro credit used at Geben in 2009)

% Repayment rate for micro-loans 93% 100% 100% for Geben Association in Maras

Average value of micro-loan (US$) 86114

1,680 400 for Geben in Maras

% Women receiving micro-loans 26% 45% 12% for Geben in Maras

Number of demonstration farms / agricultural trainers

53 demonstration field plots and 50 agricultural trainers

100 demonstration farms / 11 trainers

1585 demonstration farms were established in villages along the BTC route (365 agricultural trainers)

Number of farmers trained 4,428 farmers, additionally 60 youth participated in youth business plan

and marketing training

3,379 Over 129,000 (also 800 beekeepers)

Number of livestock vaccinated — 828 Reportedly over 790,000 livestock vaccinated

Weight of high quality seed provided 22.1 tonnes 15.4 tonnes Over 1200 tones (also over 63,000 fruits saplings provided)

Number of co-operatives established 1 Dev. Resource Centre in Yevlakh 4 Agricultural Service Centres

8 Water Purification LLC’s

25 co-operatives (15 producer and 10 service

groups are created)

70 village based organisations established (Coops, Associations and informal CBOs). CIP IPs working together

with 126 CBO s for capacity building programme.

12

Amount invested: untill 31st 2006 – accruals plus amount disbursed, from 1

st January 2007 – only amount disbursed.

13 All the data re micro-loans includes the data from micro finance projects of Sustainable Development Initiative.

14 Average value of micro-loan for year 2009 is $USD 865.


33

6.2.1 Azerbaijan

The following activities of note took place in 2009:

The Water Purification Programme Phase ll continued. This programme, which started at the beginning of 2007 and is being implemented by Umid NGO, targets communities along the BTC/SCP route that lack potable water.

The Youth Employment and Economic Opportunities Expansion Initiative helps youths living along the Baku section of the pipeline corridor through apprenticeship courses and grants for business start-ups.

The British Council began the Interactive Science Project to support student-centred, interactive approaches to teaching and learning science subjects (biology, chemistry and physics).

In June 2009 Junior Achievement Azerbaijan began to implement the Community Economics and Business Education Program – Phase II.

In November 2009 the Economic Development of the Garadaghly Community by the Strengthening of the Agricultural Sector project began. This project is being implemented by the Ganja Agribusiness Association (GABA) and provides sustainable income development for people involved in the agriculture sector.

In June 2009 the programme of Economic Development of the Khatinli Community by the Strengthening of the Agriculture Sector began. This project is also being implemented by GABA and has been designed to support Khatinli community efforts to enhance their economic development through strengthening agricultural capacity.

In August 2008 Gaba began the programme of Enhancement of the Capacity and Potential for Sustainable Development of the Eyvazlilar Human Development and Sustainable Income Generation Public Union (EHDU). The programme’s goal is to improve the quality of life and increase opportunities for sustainable livelihoods in the target areas.

In October 2009 Expansion of Economic Opportunities and Community Skills Development Program began by Umid. The goal of the project is to create better environment for entrepreneurs to build sustainable businesses and to support unemployed youth in finding employment opportunities.

In January 2009 Umid also began the programme of Management of Community Micro-projects. The program aims at equipping 39 communities from Agsu to Agstafa with the skills and resources needed to initiate positive sustainable change and socio-economic development.

In August 2009 Local Governance Assistance (LGA) Public Union began the programme of Improving of Agstafa ASC and Surrounding Communities. The goal of the program is to increase the productivity of 16 communities along BTC/SCP pipeline in Agstafa region and increase income of agriculture producers and target communities.

6.2.2 Georgia

The Operations Phase of the CIP (CIP II) was launched in August 2006 and is due to be completed in January 2010. Its main goal is to enhance positive relations between BP and communities along the BTC/SCP pipeline route through sustainable socio-economic development. Initially, a project implementation contract was signed with CARE International with the following project themes:

Community mobilisation;

Infrastructure rehabilitation;


34

Economic and agricultural development, support for business start up and provision of micro credit;

Education and youth empowerment.

CARE International has been working with a consortium of 5 national NGOs to support communities implement and sustain self–help projects, thereby improving the livelihoods and opportunities for pipeline-affected communities through a partnership relationship with BP.

Key achievements of the project in 2009 were as follows:

17 rehabilitation projects were implemented: 35% were potable water system rehabilitation projects and 47% irrigation system rehabilitation. These allowed over 1,756 households to irrigate over 1,275 ha of land plots and orchards. Planting of potato seeds and different kind of vegetables increased from 15% to 50%. Most of the villages enjoyed bigger harvests (average increase 30%) compared with previous years.

All grantee agricultural producer and service groups are functioning. More than 1,402 vaccinations were provided to cattle owned by 523 households. 137 Ha of land were tilled and 15 ha of land were cultivated with machinery received by the service groups.

All young women start-up businesses that have received support from the programme are operational. The third round of the entrepreneurs grant competition project selected 58 ladies for future funding. In total 89 grants were disbursed to start new businesses.

Rehabilitation projects were implemented in five target schools. The project continued supporting Ministry of Education reform via strengthening the capacity of the Board of Trustees at schools.

In March 2008 CIP, BTC and SCP started the “Farmers to Market” project, which is due to finish in August 2010. The main themes are:

To give farmers increased access to agricultural product buyers via establishing 4-6 Consolidation Centres.

To give farmers increased skills, knowledge and tools for improved marketing of their products.

As a result of the project, two agricultural Consolidation Centres (CC) for honey processing and packaging and milk processing were established, resulting in the following outputs:

350 kg packed honey;

4,266 kg cheese;

118,106 litres of milk collected from 188 farmers;

About 70 tons of other products.

6.2.3 Turkey

2009 was the 3rd year of Phase II CIP implementation in Turkey. During this time CIP Implementing Partners (IPs) have focused on developing sustainable income generating activities through capacity building of community-based organizations (such as cooperatives, village development associations and unions), so that these can continue to operate and prosper after the exit of the IPs from the regions at the end 2011.


35

Active projects and key achievements in 2009 were as follow:

Ardahan Sustainable Rural Development Project implemented by IBC in 37 villages:

79 women trained on beekeeping and started honey production.

Two village Cooperatives supported to establish milk collection centre. They collected over 750 tons of milk in 2009.

20 greenhouses established by project supports harvested nearly eight tons of vegetables in 2009;

Kars Sustainable Rural Development Project implemented by SURKAL in 20 villages:

Farmers trained in all project villages together with Kars Cattle Breeders Union in all BTC affected villages; animals vaccinated and inseminated

25 female and 35 male intermediaries (local villagers) trained on ex-paraziter disinfection, measuring the body temperature, conducting injection and conduction mastitis test.

Erzurum Sustainable Rural Development Project implemented by Atatürk University in 27 villages:

11 projects prepared by 22 producers from 11 project villages submitted to and accepted by the Ministry of Agriculture Support for Rural Development Projects Investment Programme 1.000.000 USD of external funds generated by these projects.

Erzincan Sustainable Rural Development Project implemented by PAR Consulting in 12 villages:

Şahverdi Village Agricultural Development Cooperative (ADC) supported strawberry producers; 18.330 kg of strawberries was harvested in 2009. Şahverdi ADC was also awarded an aid from Refahiye SPA to establish a 25 da strawberry garden in addition to the current gardens (10 da).

Sivas Sustainable Rural Development Project implemented by SURKAL in 22 villages:

50 producers from 3 villages were supported in organic production of cereals in 10.000 da of area.

Ulaş Development Association in Sivas carried out activities for disseminating organic farming with the support of CIP. 4 tons of organic products have been cultivated in 2009.

136 producers from 22 project villages have done greenhouse farming in total 9.130 m² in 2009.

Kayseri Sustainable Rural development Project implemented by PAR Consulting in 26 villages:

Hanımeli Women Cooperative’s pastry production in Kayseri increased by 50% compared to previous year. 11 local women employed by the cooperative.

Kahraman Maraş Sustainable Rural development Project implemented by IBC in 24 villages:

Geben Development Association (close to IPT1) started to provide agricultural machineries to the farmers in the region.


36

Adana-Osmaniye Sustainable Rural Development Project implemented by PAR Consulting in 21 villages

In Adana and Osmaniye Sustainable Rural Development Project (SRDP), land reclamation in Cukurova plain (which is one of the main agricultural fields of Turkey) was one of the most significant activities in 2009. Sulphur application was done on a total land of 9.800 decares (da) in the project area although 3.000 da were targeted for 2009.

6.2.3.1 Summary of the Regional Development Initiative (RDI) Programme

2009 was the 3rd year of implementation of RDI programme in Turkey. Two projects were active in 2009:

Organic Honey Production Project financed by IFC and BTC Co. and implemented by Temari in Northeast part of Turkey. This project was successfully completed. Temari still continues project activities through its own funds in Ardahan province which indicated the sustainability of the project.

Supporting Sustainable Livelihoods for Yumurtalık and Gölovası Fishermen Project: This project also concluded in 2009 and resulted in the development of an artificial reef in Yumurtalık Bay, building a scaffold winch for the maintenance of boats and establishment of a fish storing and selling facility. The project also supported alternative income generating activities such as olive cultivation (involving 20 fishermen families), pension improvement support for 3 fishermen families, welding courses for 20 fishermen sons, and hair dressing courses for female members of community. Support for fishermen communities will continue in 2010 and 2011.

Budget details for each of these projects are presented in Table 6.6

Table 6.6: Completed RDI Projects

Project Partners BTC Grant

(US$)

Partner Contribution

(US$)

Total project Funds (US$)

Temari Organic Honey production IFC 180,000 90,000 270,000

Supporting Sustainable Livelihoods for Yumurtalık Fishermen project

PAR 350,000 267,000 617,000

Total 530,000 357,000 887,000

Current projects which are being implemented together with the Government and, other development institutions are summarised in Table 6.7 below.

Table 6.7: Ongoing RDI Projects


(US$)


(US$)

Total project Funds

(US$)

Supporting the SMEs to bank credits on BTC Pipeline Route

Credit Guarantee Fund (CGF)

TC. Ziraat Bankası 2,000,000 2,000,000

4,000,000

(x5 leverage from Banks = $ 20 m USD)

Towards an Industrial Symbiosis Programme in Iskenderun Bay Area – Phase I

United Nations Development Programme (UNDP) Turkey

106,500 67,500 174,000


37


(US$)


(US$)

Total project Funds

(US$)

Employment and Enterprise Development Based on Inter-sectoral Cooperation in Çukurova Region – Phase II

National Employment Agency (ISKUR) and National SME Development Agency (KOSGEB)

1,370,000 2,032,000

1,180,440 4,582,440

Technical Assistance for Management of the Antakya Landfill Facility in line with International Standards

Municipality of Antakya & İSTAÇ

360,000 197,306 557,306

TOTAL 3,836,500 5,477,246 9,313,746

The following projects are in the planning phase:

Table 6.8: Planned Projects


(US$)


(US$)

Total Project Funds

(US$)

CEYDEM (Ceyhan Fire and Natural Disaster Training Center)

Çukurova Regional Develop-ment Agency, Çukurova University,

Rescue and Research Foundation (AKUT)

400,000 500,000 900,000

Industrial Symbiosis – Phase II

UNDP and other donor organisations (tbd)

tbd tbd tbd

6.2.4 CIP Expenditures 2009

CIP expenditures for the total Operations phase and for the year 2009 are summarized in Tables 6.9 and 6.10.

In Georgia CIP II expenditures for 2009 included expenditures associated with the CIP II 3rd year contract, which was completed in July 2009, but was extended until the end of 2009.

Table 6.9: Operations Phase CIP II Budget and Expenditures ($), 2006-2009 (BTC/SCP only)


CIP II Budget 8,165,097 4,472,21415

9,650,000 22,287,311

Total Spend up to the end 2009 7,130,524 4,084,477 9,650,000 20,865,001

Table 6.10: Summary of BTC/SCP CIP II Expenditures ($), 2009


Planned 1,282,500 1,111,596 2,400,000 4,794,096

Actual 2009 923,36316

1,061,443 2,400,000 4,384,806

15

CIP II 1st year contract value was $1,470,000;CIP II 2

nd and 3

rd year contract value is $2,390,000. 6 months extension

value is $92,214. the project “Farmers to Market” contract value is $520,000. 16

Actual commitment based sum.


38

6.3 CIP BUDGET, 2010

The BTC CIP II budget for 2010 is presented in Table 6.11 below.

Table 6.11: BTC CIP ll Budget ($), 2010


Budget 2010 855,00017

387,737 2,900,00018

4,142,737

7 E&S MONITORING PROGRAMME

7.1 INTERNAL MONITORING

Internal monitoring takes place as necessary on a daily basis or through theme audits and reviews. In some cases the review might result in actions and recommendations for implementation.

Non-compliances are only raised by BTC or BIL in certain circumstances, generally for persistent issues that need management attention. If the matter can be rectified in a timely manner through local site intervention, a non-compliance is not generally raised. The status of all internal non-compliances raised is given in the relevant country sections in this Chapter.

BTC has also developed a set of tools to assist in the management of E&S issues including detailed monthly reports and quarterly performance reviews.

Detailed summary of internal ESMS monitoring commitments completed during the year is provided in Section 4.2 and monitoring results in Appendix 2.

7.2 EXTERNAL MONITORING

7.2.1 Host Government Monitoring

7.2.1.1 Azerbaijan

In April, 2009 a letter complaint was received by MENR from a Chohranli village resident of Kurdamir Region. The basis of the complaint was that, after completion of pipeline reinstatement works, the soil surface had not been levelled adequately and this inhibited sowing activities. BP met with representative of MENR, provided detailed documentation and relevant information regarding the complaint, arranged a visit to the area and conducted a thoroughly investigation. A Joint site visit involving BTC and MENR concluded that the complaint was not grounded.

As a condition of MENR approval for the Small Scale Erosion Control Works at River Crossings on the BTC/SCP and WREP ROWs. A MENR representative conducted an inspection in July.

7.2.1.2 Georgia

BP coordinated bi-weekly meetings with Georgian Oil and Gas Corporation (GOGC) and the Ministry of Environment. Other meetings were held with the Georgian Prime Minister and the Ministers of Energy, Economic Development, Interior, as well as governmental bodies.

17

Consolidated social investment budget for Az EIP & CIP. 18

Consolidated social investment budget for Tu CIP & RDI


39

7.2.1.3 Turkey

Employment Standards Audit by Ministry of Labor and Social Security:

The Ministry of Labor and Social Security audited BIL activities at all Pump Stations (PT1-PT2-PT3-PT4), IPT1 and CMT for 20 days between May and June 2009. In total, 1,296 personnel employed at the facilities were reviewed during the audit (471 by BIL and 825 by sub-contractors/service providers). Their social security insurance was also verified by the Ministry Inspectors (see also Section 11).

MoEF Audit of Antakya Landfill Facility:

BTC Co. developed a project with İSTAÇ A.Ş. (the company manages Istanbul Municipality’s waste) to upgrade the Antakya Landfill facility so that it could meet EU standards. Once this was achieved the plan was for BIL to send their domestic waste to Antakya (which is very close to CMT and IPT1) rather than to the distant Izaydaş facility (close to Istanbul).

After the upgrade was completed MoEF representatives were invited to audit the facility prior to providing the license as per Turkish regulations. Two main outstanding items were identified by MoEF which delayed the permitting process;

Part of the facility was not fenced

The access road in the facility was not suitable for the operation

The Municipality is expected to rectify these matters in 2010, following which BTC Co. will commence the permitting process.

In addition to above, representatives from Provincial Directorates of MoEF and State Hydraulic Works (DSI) Turkish regulatory authorities visited BVT30 and CMT in 2009. The main purpose of the visits was to seek information on the final status of MARPOL facility at CMT and BVT30 monitoring activities in Erzincan.

7.2.2 NGO Monitoring

7.2.2.1 Azerbaijan

No NGOs monitoring took place in 2009.

7.2.2.2 Georgia

Due to lack of interest from NGOs towards BP/BTC operations in the country, formal NGO monitoring of BP/BTC activities in the country has stopped. Informal activities and engagement continued however to keep the NGOs and general public informed about BP’s operations. In June 2009 BP took part in the forum organized by the UN Global Compact Georgia network and used this opportunity to present its sustainability report and provide an update on ongoing company activities.

More information is provided in Section 8.3.2.

7.2.2.3 Turkey

In Turkey a facilitating/capacity building organisation is not being used as in Azerbaijan and Georgia. As many national NGOs are already involved in the Project their experience is generally greater so there was a lack of demand for a facilitated scheme. Notwithstanding this, BTC Co. and BIL continued to engage both national and regional stakeholders to discuss specific issues on an as needed basis.


40

7.3 TRAINING

7.3.1 Azerbaijan

Training for BTC Operations continued to be delivered to both BP and contractor staff through a variety of media including formal classroom trainings, tool-box talks, roll-out of respective environmental procedures, aspects and impacts, objectives and targets, etc. on the base of developed Environmental Training matrix. Training was provided on key operational environmental issues such as waste management, emissions management and HSSE Policy. In addition training on specific topics such as cultural heritage and faunal protection was given to ROW personnel. The environmental element in HSE induction has been updated in order to fulfill awareness of all new staff arriving at BTC facilities.

7.3.2 Georgia

Training for BTC Operations in 2009 focused on ESMS and ISO 14001awareness. Other key issues included site personnel training on the following topics: a) AGI and ROW environmental aspects and impacts management, b) pollution prevention and housekeeping and c) waste management procedure specific trainings.

Training was delivered mostly at sites through formal classroom training as well as toolbox talks.

7.3.3 Turkey

In Turkey, BIL continued to provide environmental and social training to operations and maintenance teams, subcontractors, etc. Training topics were wide in scope and have been tailored to the departmental teams according to their roles.

Site specific and role specific environmental training was provided on the following topics:

Waste management (segregation, collection and storage)

Management of vegetable oil wastes

Role specific training to drivers

MSDS awareness

Chemical handling and storage

Oil spill response training (by ER management)

A two phase hydrogeology training for oil spills was also held by BTC Co. which involved BIL HSE Engineers and BTC Co.’s and BIL’s Environmental and ER teams.

Further, in 2009, ISO 14001 lead auditor and OHSAS 18001 trainings were provided for BIL Environmental team.

BIL PCREs provided training to all new employees of BIL and contractors as part of the orientation programme (in total 226 employees were trained in 2009). These training programmes covered the following topics:

Community Relations (Organization & Responsibilities)

Complaints & Compensations

Employment

Procurement

Safety (Traffic & Pipeline Safety)

Land Use / Restrictions


41

Code of Conduct

Audits (Internal and External)

Responding to Media

Community Investment Programmes

Refreshment of PCR Training

Communication Skills

In 2009, all BIL PCRE team members and BTC Co. CSR team members received SA 8000 Internal Audit training.

8 PROJECT COMMUNICATION

8.1 CONSULTATION APPROACH

Consultation and communication with various Project stakeholders, from communities to Government organisations, was ongoing during 2009 with the key objective being to avoid situations that could lead to complaints. Where complaints do arise, as is inevitable for a project of this size and complexity, effort is made to ensure they are resolved promptly. Information on complaints raised by project affected communities is detailed below.

Across the Project significant efforts were also made to engage other Project stakeholders, government ministries and the local and national media. Information on meetings held with key stakeholders in 2009 is provided below.

8.2 AZERBAIJAN

8.2.1 Project Affected Communities

There were a number of community relations initiatives launched by the Operation’s social team in response to various requests from Project Affected Communities.

Due to the request for additional information from state administrations and community members the Operations Social team has doubled the subjects covered at its community consultation meetings. The subjects now covered include:

Grass fires; Illegal crossings, land use rules and restrictions; waste management along the pipeline route; pipelines integrity; weight restrictions applied to the agricultural equipment used within the pipelines corridor, conditions of operations for irrigation canals, allotment of pipeline-affected lands to new land users, and work plans of government agencies and enterprises within the ROW.

8.2.1.1 Interim Routine Right of Way Access Strategy

A key part of the Access Strategy was to acquire a 6m wide access track within the ROW corridor. This process necessarily involved extensive consultation, in accordance with RAP principles, which was independently monitored by the NGO Center for Legal and Economic Education (CLEE).

8.2.1.2 Complaints

In 2009, the Operations Social team received eight complaints from land owners and users within the pipeline ROW in Azerbaijan – 30% less than in 2008 (Table 8.1). By the end of 2009, all outstanding complaints had been resolved.


42

Also, during 2009 Social Team closed six complaints that were outstanding from the previous years. The majority of these related to compensation.

Table 8.1: Summary of Complaints received by BTC/SCP, 2009 (Azerbaijan)

Complaint Category Complaints received Complaints open at end of 2009

Reinstatement 1 0

Compensation 5 0

Parcel ownership and size 1 0

Land use 1 0

TOTAL 8 0

8.2.2 NGOs and Technical Organisations

Regular meetings were held by Community Liaison Officers and the Sustainable Development Initiatives Team with a range of national (Umid, Madad, GABA, LGA) and international (Junior Achievement Azerbaijan, Save the Children, FINCA) Implementing Partners to discuss progress of Community Development Initiatives.

8.2.3 Government

Communications with Government during 2009 are discussed in Section 7.2.1.1.

8.3 GEORGIA

8.3.1 Project Affected Communities

The BTC Social team continues to work and communicate with local communities on a regular basis. CLOs maintain constructive relationships with communities in districts crossed by the pipelines and the Company continues to inform communities on land use restrictions, safety issues, how they can lodge a complaint, etc. Communications with district governors continues.

A summary of the main activities conducted in 2009 is as follows:

The Social team continued working with Contractors both at management and field level to ensure understanding and compliance with social commitments.

Social Awareness Training was conducted at all sites for key Operations staff and contractors. 80% of all Company staff was covered. Social Awareness Training for security guards was conducted jointly with the Voluntary Principles training and 161 guards were trained;

In order to increase community engagement and reinforce key message BTC Co. developed the Community Calendar for 2010. The calendar also contains information on energy efficiency which serves to increase community awareness in this area.

In March a contractor conducted a quantitative survey of AGI affected households as part of the RAP completion process. In addition in September an SRAP Panel member and an IFC representative conducted a 10-day qualitative field survey that involved interviews with landowners, community members, complainants, village heads, district officials, NGOs and BTC Co. management. The overall conclusion was that livelihoods had been substantially restored or enhanced with the exception of some pockets within the intensively cropped agricultural land.

During 2009 all BTC community village profiles were updated and uploaded into a new community database system. This is now linked to the complaints log, thereby allowing community issues to be better managed.


43

8.3.1.1 Complaints

The Company continued effective management of the 3rd Party Complaints Procedure. Communities are aware of how they can raise grievances and CLOs helped them to lodge complaints when necessary. During 2009 year 45 complaints were received of which 42 have been closed. Table 8.2 gives breakdown of complaints categories. There remain two outstanding complaints from 2007 for which BTC has resolution plans in place.

Table 8.2: 2009 Complaints Log Statistics (as of December 2009)

Complaint category Total number received to date

Number of complaints

resolved

Total % of complaints

resolved

Number of complaints

pending

Additional Land 1 1 100% 0

Land Handback/Reinstatement 4 4 100% 0

Orphan Land 0 0 100% 0

Other Land Issues 7 6 86% 1

Access Restricted/Abolished 7 7 100% 0

Inventory/compensation disagreed 9 9 100% 0

Parcel Ownership or Size 0 0 100% 0

CBO Compensation 0 0 100% 0

Community Infrastructure 4 3 75% 1

Household Infrastructure 4 3 100% 1

Bee-Related 1 1 100% 0

Irrigation 2 2 100% 0

Cracked house 1 1 100% 0

Employment 3 3 100% 0

Other Social Issues 1 1 100% 0

Miscellaneous 1 1 100% 0

TOTAL 45 42 93% 3

8.3.2 National NGOs and Technical Organisations

In 2009 BP/BTC continued to engage with national NGOs through a range of different initiatives. These initiatives are: a) Environmental Investment Program b) Community Investment Program C) Different cultural heritage initiatives.

BP/BTC also actively participates in the different conferences and forums organized by the UN Global Compact Georgia Network. This creates an excellent networking opportunity with different stakeholders – NGOs, businesses, other national and international organizations.

8.3.3 Government Ministries and Departments

Close contacts were maintained with GOGC, including by-weekly meetings with MoE involvement. Relationships continued with various ministries and departments: Ministry of Economic Development, Ministry of Environment, Ministry of Energy, Ministry of Justice, Ministry of Infrastructure and others. There were positive outcomes for a number of important issues including eco-compensation for forest affection during construction, land category change for BTC SCS, regulatory clearance for the initial stage of WREP SR Project and numerous GoG sponsored 3rd party works in ROW.


44

8.3.4 Media

During 2009 various media activities took place in Georgia including:

A round table arranged for the local media in order to discuss and disseminate the company’s Sustainability Report

A press release was issued and interviews recorded during the Award Ceremony of Eco- Awards Program involving BP management, government, scientists, local NGOs and media.

A media trip was arranged to communicate the results of the CIP

A press release was issued regarding a special performance staged under the cultural exchange program between Rustaveli Theatre and UK National Theatre. This was sponsored by BP and HSBC in partnership with the British Council.

A press release was issued and interviews recoded with BP’s General Manager during the Project Management College launch event attended by Georgian government, international organizations, businesses and media.

A press release issued and interviews recorded with BP’s General Manager for the Energy Efficiency Program – Energy Bus project launch attended by Georgian government, international communities, businesses, NGOs and media.

8.3.5 Donor Organisations

BP/BTC continued to meet with various development organizations in Georgia including: UNDP, USAID, World Bank, IFC, Millennium Challenge Commission Georgia and several national and international NGOs.

BP/BTC and its co-venturers, in collaboration with number of international organizations, continue to implement a number of projects in Georgia, including: Georgia Enabling Business Environment Project (IFC); Corporate Governance Project (IFC), Technical Assistance and Landing Support to Constanta Foundation (EBRD), Energy Efficiency Project (USAID, EBRD, OSCE, EBRD), Georgia Food Safety Project (IFC); English Language Program for Media (OSGF/British Council).

Regular talks with donor organizations and participation in different coordination meetings continue with the aim of defining potential areas for future engagement.

8.4 TURKEY

8.4.1 Consultation

8.4.1.1 BIL

The main highlights of consultation activities conducted in 2009 are as follows;

The RAP completion audit was conducted to asses whether the project affected peoples’ living standards and income levels have been fully restored.

52 villages along the pipeline route and 8 villages around AGIs in 10 provinces along the route, were surveyed, resulting in interviews with 838 people.

Several landowners/users from 20 villages, local authorities, Chamber of Agriculture, cooperative heads and village leaders were interviewed by the SRAP Panel during a survey conducted in June 2009. Initial results indicated that there were no significant issues other than some outstanding reinstatement complaints that were still being resolved by BTC Co. Over 60% of the surveyed people found CIP activities beneficial and stated that project activities such as income generation and animal husbandry had a positive impact on their income.

The final report is awaited from the SRAP Panel.


45

Other consultation activities performed during 2009 are as follows:

The BTC Co. Social Team continued to work very closely with the Project and Environment teams to close out the reinstatement complaints along the BTC route. All residual complaints from Ardahan to Kahramanmaraş provinces were actioned by end 2009. Complaint close out forms were signed by each landowner/user at the end of reinstatement activities.

In order to monitor the employment standards in BTC Operations, BTC Co. engaged the Ministry of Labour to conduct an audit at all locations along the route. The audit took 2 months of site work including CMT, all PTs and IPT1. No major non-compliance with the Turkish Employment Law was found.

Introductory meetings were held with all affected village leaders (Muhtars) along the pipeline route, who were elected during the local elections on 29th March 2009. BIL PCREs introduced themselves and left their contact details. Information provided to all Muhtars with regard to the project including land use restrictions, and venues for lodging complaints. Villagers also attended these meetings.

8.4.1.2 Community Meetings

In total 529 community meetings were organized by PCREs during 2009. This figure does not include consultation meetings with affected villagers conducted by BTC Co. and by its implementing partners for CIP and RDI related issues. A breakdown of meetings held by BIL in 2009 is shown in Table 8.3.

Community pamphlets which provide information on land use restrictions, emergency response, security, venue for grievance log, etc. were distributed to all villages and other local stakeholders such as sub-governors, mayors and state officers by PCREs during these meetings.

In addition BTC Co. financed the establishment of Village Information Boards in 300 villages along the pipeline in 2008 where posters on land use restrictions, emergency phone numbers, PCRE contact details and CIP related information are displayed. In 2009 information on these permanent village information boards was updated and some were renovated.

Table 8.3: BIL Community Meetings, 2009

BIL Community Meetings No. of Village Meetings

Stakeholder Meetings

Introductory Meetings 26 4

Community Awareness and Consultation Meeting 127 19

Regular Meetings (follow-up to introductory meetings) 157 38

ER/Oil Spill Drill Notifications 8 3

Land-use Restriction Notification meetings* 22 -

Women Meetings 7 -

Third-party Crossings* 39 2

SRAP Audit 9 -

Illegal Tap Consultation Meetings/ROW Security** - 18

Other (holiday courtesy visits; response to particular issues, etc.) Evaluation Meeting with BTC Co.

11 39

1.2 Expansion works consultation meeting - -

TOTAL 406 123

* The scope of introductory and regular follow-up meetings includes land-use restrictions and third-party crossings. These subject specific meetings were held in most cases to re-emphasise these issues where considered necessary.

** As there were no illegal taps in 2009 no consultation meeting on this issue was held. Security forces and relevant authorities were consulted on this subject.


46

8.4.1.3 Regional Stakeholders Meetings

BIL stakeholder communication included consultation meetings with the local gendarme, provincial governors, district sub-governors, mayors, government utility providers, and other relevant government departments. The purpose of these meetings was to introduce BIL and discuss restrictions regarding land-use, third-party crossings and emergency response issues. Throughout the year the PCR department of BIL continued to host official visitors at CMT including country representatives, government officials, media and NGO representatives.

8.4.2 Complaints Management

During this reporting period 89 complaints were received, as shown on Table 8.4.

As reported in last year’s report, BTC Co. and BIL visited all villages and interviewed with landowners/users to ensure any remaining issues from construction or post construction phase are identified and resolved. All of the recorded reinstatement related complaints in Lot A and Lot B (in total 223) were resolved in 2009 by a contractor under direct management of BTC Co. with the support of BIL PCREs. Complaint close out forms were signed by each landowners in line with the Grievance Procedure. The tendering process is ongoing to reinstate the problematic areas in Lot C in 2010.

In 2009 most of the newly registered complaints were related to land repair and compensation for damages associated with construction works, the BVT30 incident and payment to service providers for operation. With 304 remaining complaints from 2008, and 89 new complaints logged in 2009 total complaint number for 2009 is 393. However 164 of them were found to either be unfounded by external reinstatement experts and/or already registered as a complaint.

Therefore the number of open complaints at the end of 2009 was 229, of which 42 are about to be concluded. Complaint close out forms will be signed in 2010.

The second highest number of operational complaints received in 2009 was related to compensation payments for the construction camp sites. BTC Co. and BIL have initiated a joint study to evaluate permanent land acquisition needs for camp sites in 2010. This is expected to help to resolve the camp payments issue.

Table 8.4: Total Number and Category of Operation Complaints received, 2009

Subject 2008 2009

Employment 7 0

Reinstatement* 390 58

Access to land and other resources 2 0

Damage to property, crops and land 20 4

Damage to infrastructure and community assets** 77 7

Dust & Noise 0 1

Payment/Payment to service provider 22 14

Local Procurement 1 0

Outstanding expropriation payments 17 2

Misconduct of BIL employees 0 0

CIP – perceived inequity in distribution of support 5 1

Decrease or loss of livelihood 3 1

Other (3rd

party crossing – Use of local resources) 2 1

TOTAL 546 (residual open 304 by end 2008)

89

* Includes reinstatement, biorestoration, border, grading, riprap, soil, transportation, stone complaints

** Includes damage to channels, irrigation channels, drinking water, drainage, water source, road, bridge


47

Table 8.5: The category of remaining open complaints for 2010 (# 229)

Subject 2010 Action Plan

Reinstatement 54 In the scope of 2010 reinstatement plan. Tendering process is ongoing.

Border issues 33 In the scope of BIL PCRE’s action plan for 2010.

Geohazard 11 In Geohazard team scope for 2010.

Damage to tree 4 These are the trees planted as part of offset mitigation however landowners want

to remove them now.

Biorestoration 2 In the scope of 2010 reinstatement plan. Tendering process is ongoing.

Operational issues; ROW maintenance related reinstatement, compensation issues, etc.

83 In the scope of BIL ROW monitoring and maintenance team for 2010.

Second crop payments 19 Not legitimate but close out forms to be signed.

Complaints waiting for close out forms

23 Action taken but close out forms not signed yet.

TOTAL 229

8.4.3 BTC

8.4.3.1 Consultation Activities with Government, NGOs and Other Donor Institutions

BTC Co. also undertook various stakeholder meetings as part of its assurance role in Turkey. The majority of the meetings were related to investment programmes (EIP, CIP and RDI), however some social and environmental issues associated with reinstatement activities in Lot A and Lot B were also covered.

BTC Co. held several meetings with stakeholders for investment projects including local, regional and national government representatives, development/donor organisations such as UNDP, national and international NGOs, universities and private businesses. The objectives of the investment stakeholder meetings were to raise awareness and support for the investment activities, promote cross-learning across villages and municipalities, understand government and NGO future priorities and strategies, seek additional funds, etc.

In 2009, two main CIP&RDI workshops were held to discuss the progress in CIP and RDI projects and also to shape the future activities together with implementing partners (IPs). These workshops involved all IPs, representatives of local NGOs, cooperatives, local Government and other donors.

A summary of the number of meetings or other formal communications held by BTC Co. is shown on Table 8.6. Note that the number of meetings held does not include meetings held by EIP and CIP IPs. The IPs held many district and village level meetings in addition to those shown on the table below.

Table 8.6: BTC Stakeholder Meetings, 2009

Type of Meeting No. of Consultations*

Donor 10

Government 20

NGO 25

Private companies 18

University 10

TOTAL 83

* In some cases, consultation can represent a series of meetings on the same subject.


48

8.4.3.2 Media

BTC Co. is managing relations with media institutions in Turkey in line with the Operating Agreement with BIL. Several press events were organised to disseminate information about the progress of the BTC project as well as to launch CIP & RDI projects.

9 LAND ACQUISITION AND COMPENSATION

The land acquisition, compensation, hand-back and livelihood restoration activities and processes are described in the Resettlement Action Plan (RAP). This section of the report summarises relevant activities conducted in 2009.

9.1 AZERBAIJAN

9.1.1 Land Acquisition, Exit and Compensation

The primary land acquisition and compensation process for the pipeline ROW in Azerbaijan has been successfully completed. As noted in previous Annual Reports, bank accounts have been established for all affected people, in all districts, except for nine unavailable landowners (compensation for these owners has been retained until such time as they are located). Relevant compensation has been paid to 99.9% of the land owners/land users.

At present there are 54 cases where the Land Lease Agreements’ Addendum (for the prolonged construction period) has not been signed by landowners/land users (SLAP 1 and SLAP 2). The main reasons for this situation are the absence or unavailability of landowner/land users as a result of being out of the country, having died, being in prison or as a result of heritage family disputes. BP monitors such cases and if the landowner/user becomes available, the agreement will be signed and compensation paid. The agreed action plan for closure of these outstanding land exit agreements has been developed on a village by village basis and comprises assigned responsibilities and suggested budgets.

In other developments:

4 informal land users from 14 villagers (Hajialili village, Shamkir district) have elected not to sign the agreement

4 land owners have elected not to sign the agreement

The land exit process has been implemented by the project with the help of local land committees and continues to be monitored by the project social team along with the third party NGO, CLEE. No issues or concerns were reported.

9.1.2 Land Acquisition Program for 6m Access Corridor for Interim Routine Right of Way Access Strategy

As the part of the ESIA and RAP compliance, BTC acquired a 6m land strip alongside the RoW as some sections were used for the temporary driving of Azerbaijan Government EPPD vehicles (refer Section 2.4.1). This land acquisition process consisted of the following stages: consultation with landowners/land users, notification, agreement signing, land entry, compensation payments and at the end, land exit.

During 2009 the following activities were accomplished:

Signing of the Addendum to agreements and Land Pre-Entry/Exit Agreements with 45 landowners/users and compensation paid;


49

Signing of agreements and Land Pre-Entry/Exit Agreements with 5 new landowners/users and compensation paid;

22 complaints solved/compensation paid.

9.1.3 AGI Certificates Change

As a result of the land acquisition associated with the construction of the AGIs, 31 landowners did not obtain new land certificates showing the new land boundaries. As an act of good will, the third party legal NGO CLEE was hired by BTC to assist the affected landowners redress this situation. This involved payment of the state registration fee on their behalf and assistance in collecting all necessary legal documents to apply for the new land certificates.

As a result, 24 out of 31 landowners have now received their certificates. In one case the landowner has passed away and relevant the heritage documents are being prepared. The remaining 5 landowners will soon to receive their certificates. This process is planned to be completed in 2010.

9.2 GEORGIA

9.2.1 Acquisition and Compensation

As of December 2009, land acquisition in Georgia is nearly complete. To date a total of approximately $12 million has been paid out for land acquisition and approximately $12 million has been disbursed as compensation for crop loss. Table 9.1 summarizes key information regarding the acquisition, compensation and hand back of land used.

It is noteworthy that a large number of errors in the state land registration and documentation system were identified and rectified throughout the land acquisition process. One outcome was that the number of land parcels involved in the compensation process grew from 2782 to 3522.

Table 9.1: Number of Land Parcels for which compensation has been paid (to end December 2009)

Private Land Parcels

High Mountain Village Land Parcels

State Leased Land Parcels

District Required Actual Required Actual Required Actual

Total 3,522 3,478 206 206 239 226

% Complete - 99% - 100% - 95%

9.2.2 Land Registration and Ownership

Some of the ongoing court cases regarding land registration and titling have not yet been finalised. Additional payments may be necessary, for example in Naokhrebi where BTC has appealed against a ruling that affects 62 parcels of land.

In addition, BTC has acquired Necessary Rights of Way (NROW) for land owned by 28 absent landowners. Future resolution may prove to be a challenge owing to fluctuating land prices.

9.2.3 RAP Fund

The budget for land acquisition and RAP costs for the Georgia section of the BTC pipeline project was estimated to be $10.8 million. The actual expenditure amounted to $24 million. The major elements were: payments for permanent privately owned land acquisition - $12 million, Crop - $8.3million, Orphan Land - $3.7million.


50

9.2.4 Land Hand-back

As of December 2009, Akhaltsikhe camp is scheduled to be reinstated in 2011 after the construction of permanent accommodation facility near Area 80 is complete.

Land exit agreements are still being signed with landowners and land users. As of December 2009, 83% of all Land Use and Servitude Agreements have been completed. The reasons for delay in signing of land exits vary but many relate to absence of landowners (101), and changes in regulations for state registration.

9.3 TURKEY

9.3.1 Acquisition and Compensation

Table 9.2 provides an update of the status of the acquisition and compensation process as of end 2009.

Table 9.2: Land Acquisition and Compensation Progress (December 2009)

Indicators Information Provided by Botaş DSA (DSA Monthly Report: December 2009)

Total (by parcel)

Complete (#) Complete (%)

Overall Land Acquisition* 16,834 16,592 98.56%

Title Deed Registration for private lands only

11,748 11,640 99.08%

Resolution of Article 10 Cases

7,708 7,632 99.01%

Transfer or Rights to Land to BTC Co.**

17,942 17,376 96.85%

*This figure includes all private and public parcels subject to land acquisition for pipeline ROW, energy transit lines, AGIs, and additional land needs for operations, etc. Change in the statistics compared to previous reports is due to the parcels being subject to transfer, owing to different configurations.

** This figure represents the title deeds acquired as a result the expropriation of 16,834 parcels which were subject to local cadastre works, and gathering and/or dividing of parcels during the land acquisition.

Throughout 2009 Botaş/DSA (Designated State Authority) has been trying to finalise the acquisition process, mainly for additional land identified during the as-built survey, and additional land needs for operations (such as security road around CMT, etc.). At the end of 2009, 97.99% of land was ready to be transferred to BTC Co. and 96.85% of these land rights were transferred to BTC Co. BTC Co. continued to monitor the acquisition of additional lands directly and will continue to monitor this process closely during the operation phase.

9.3.2 Land Management during Operations

BIL and Botaş/DSA signed a protocol which outlines future roles and responsibilities between DSA and BIL during Operations (refer to Section 8.4.1.1 of the 2008 BTC E&S Annual report). As a result all additional permanent land needs are addressed by Botaş/DSA and are required to conform to the principles described in the RAP.

Temporary land needs required for BTC 1.2 Expansion were managed by BTC Co.’s social team with the support of the contractor and BIL PCREs. All land entry and exit forms and payment documents were signed and documented by BTC Co. No issues are outstanding with regard to BTC 1.2 Expansion works.


51

Rental payments to camp sites at all pump stations were delivered by BIL PCREs by end 2009. Due to the permanent need for these camp locations, BIL and BTC Co. are considering acquiring these areas permanently in 2010. A field study will be conducted to ensure lands that are not needed for camp locations are handed back to the original landowners.

The other major land acquisition activity in 2009 was expropriation of a security road around CMT. This land was owned by Treasury and there was no impact on individuals.

9.3.3 Transfer of Land Rights

Efforts to complete the transfer of land rights to BTC Co. continued on a district basis using two Official Acts: 1) private/customary owned land; and 2) state/forest owned land.

By the end of 2009 approximately 97% of parcels had been transferred to BTC Co. The process will continue in 2010 for those parcels that were not ready for transfer mainly due to on-going cadastral works, court cases and due to the administrative process at the title deed offices (registrations). The aim is to finalise the transfer of the remaining land rights in 2010.

9.3.4 RAP Monitoring

9.3.4.1 Internal RAP Monitoring - BNB (formerly RUDF)

Due to completion of the land acquisition activities, except for a few parcels for BTC expansion and security road around CMT, and due to the fact that BTC Co. managed the land acquisition and construction works directly, BNB monitoring did not continue in 2009.

The internal monitoring role was covered by BTC Co. Social team for all additional land needs in 2009. Land entry, exit and compensation forms were signed by each landowner and documented in the BTC Co. office.

9.3.4.2 Fishermen Monitoring

No additional monitoring activity was conducted in 2009, however engagement with fishermen on CIP and operational issues continued.

Fisheries experts in Çukurova University and CIP Implementing Partner, PAR Consulting continued to design and implement community investment projects targeting fishermen in 2009 based on the social and economic survey and extensive consultation results in 2008.

Several project activities including improvement of fishing, alternative income generation, vocational training and, agriculture were implemented successfully (refer to case study presented in Appendix C3).


52

10 SUMMARY OF KEY HEALTH AND SAFETY STATISTICS

The majority of targets and key performance indicators set at the beginning of 2009 both for Projects (construction) and Operations were met. All construction and operational activities were conducted in a safe manner without any major incidents (MI) or high potential incidents (HiPo).

Construction and Operational activities were conducted across the three countries, although work carried out by the construction team was limited.

Table 10.1 presents an overview of cumulative BTC performance in Project (construction) and Operations.

Table 10.1: BTC (BP Controlled) H&S Performance

BTC Statistics for 2007



Number of Contractors submitting data 32 42 45

Total man-hours 3,333,635 3,534,100 3,263,261

Project Reportable Fatality 0 0 0

DAFWC 0 0 0

DAFWC f rate 0.00 0.00 0.00

Notes:

200,000 man hours is used to calculate DAFWC frequency

DAFWC: Days Away from Work Cases (frequency)

At the beginning of 2009, the Azerbaijan and Georgia section of the BTC project was audited by representatives from BP Global to assess safety and operations of the pipeline. The audit focused on delivery of gHSEr (Getting HSE Right), number of standards (Driving Safety, Integrity Management, Control of Work), the Compliance Management Framework, BP policies and procedures and applicable legal requirements (see Section 10.2).

10.1 BTC PROJECT (CONSTRUCTION) H&S PERFORMANCE

In 2009 a number of small projects were completed. The biggest was the BTC 1.2 expansion project which required the construction and commissioning of DRA (drug reduced agent) injection kits and storage shelters at all pump stations in Azerbaijan and Georgia. All project activities were subject to the vigilant attention of H&S personnel, who worked closely with contractors to impose high safety standards and culture. As a result, 2009 was successfully completed without any major incidents and recordable illnesses/injuries. Personnel were also actively involved into BOSS and SOC programs as shown in Table 10.2.

Table 10.2: BTC Project Leading Indicators

Project Inputs 2009 Target 2009 Performance

Safety Observations and Conversation (SOC) 100% 226%

Behavioural Observation Safety System (BOSS) 100% 136%

Safety Training Matrix Compliance >95% 164%


53

Table 10.3: BTC Project Lagging Indicators

Project Performance Outputs (Actual) 2009 Project to Date

Man-hours 1,281,350 115,713,628

Fatalities 0 10

DAFWC 0 56

Medical Treatment and Restricted Work 0 280

Recordable Illnesses/Injuries 0 287

Total Recordable 0 633

First Aid Cases 1 1,271

Near Misses 10 842

Traffic Vehicle Accidents 0 418

Kilometres Driven 3,443,832 219,211,945

10.2 BTC OPERATIONS H&S PERFORMANCE

2009 was a year of challenges for BTC pipeline operations. Parallel to the BTC 1.2 expansion project and normal operations, the pipeline went through Safety and Operational Integrity Audit across Azerbaijan and Georgia.

As a result of the audit, BTC Operation was assessed to be in a full compliance with BP Group Standards on Control of Work and Driving Safety. No examples on non-compliance with applicable legal requirements were found. The majority of recommendations addressed gaps identified in Compliance Management Framework and emergency response.

By the end of 2009 the majority of recommended actions were closed (72%) with zero recycle rate meeting exceptional performance targets on actions closure.

Following S&O audit recommendations, a review of Emergency Response Plan and arrangements were conducted in 2009. This review resulted in formalizing the interaction with Ministry of Emergency Situation of Azerbaijan and access to fire fighting resources at Sangachal Terminal.

In addition two extensive safety related programs were launched in Azerbaijan: H&S Advisors Competency and Driving Enhancement programs.

In 2009 Georgia hosted a cross country Exports Performance Unit forum in Health and Safety. The Incident Management team was fully nationalized and the Oil Spill response cross boarder exercise to test preparedness was successfully completed.

In Turkey the majority of activities concentrated on Emergency Response and Crisis Management, particularly fire fighting capabilities. A Fire Design Review was conducted for Ceyhan Marine Terminal and a Fire Peer Review for Pump Station/BVT and CMT. Additional fire fighting equipment was purchased (RRV, Industrial Fire Truck, OSR Truck). A CMT fire fighting team competency assessment was completed.

Overall, in 2009 there was no MI, HiPo or DAFWC (Major Incident, High Potential Incident or Day Away from Work Case) at the BTC operation. The pipeline experienced four recordable injuries at BP controlled facilities in Azerbaijan and Georgia and six at BP influenced facilities in Turkey.

A summary of H&S performance during 2009 for Operations activities is presented in Table 10.4 (Leading indictors) & 10.5 (Lagging Indicators).


54

Table 10.4: BTC Operations H&S Leading Indicators

Operations Inputs Target 2008 Performance 2009 Performance

BP BIL BP BIL

BOSS 100% 127 18 185 219

SOC 100% 96 4 165 42

Safety Training Matrix Compliance >95% 210 34 130 79

Table 10.5: BTC Operations H&S Lagging Indicators (Actual)

Operations Outputs 2008 Performance 2009 Performance

BP BIL BP BIL

Man-hours 1,565,302 2,328,066 1,981,911 2,191,368

Fatality 0 3 0 0

DAFWC 0 1 0 0

Medical treatment 3 2 3 5

Restricted Work 0 2 1 1

First Aid Case 4 10 7 7

High Potential Incident (HiPo) 0 0 0 0

TVA 4 8 4 8

KM driven 5,344,789 5,989,249 6,276,594 5,992,997

Near miss 34 13 31 7

BP = BP operated section of BTC (Azerbaijan & Georgia) and the BTC Assurance Team in Turkey

11 AUDITS

11.1 INTERNAL REVIEWS

11.1.1 Azerbaijan

Internal environmental inspections, reviews and audits continued to be carried out at both AGIs and on the ROW. A full summary of internal reviews and audits is given in Table 11.119.

Table 11.1: Summary of Internal Reviews/Audits, Azerbaijan, 2009

Audit/ Review

Auditor Scope Findings and/or Recommendations

ISO 14001 Internal Audit

Audit team consisted of environmen-tal advisors across AzSPU assets

BTC/SCP readiness for the ISO 14001 re-certification audit scheduled for October 2009

No major gaps were identified with respect to EMS documentation and implementation of the EMS on site. The audit team concluded that BTC/SCP were adequately prepared to undergo the scheduled ISO 14001 re-certification audit in October 2009.

Subject matter expert audit on GHG emissions reporting


Status of BTC/SCP GHG emissions reporting against applicable legislative requirements, lender requirements, AzSPU procedures and international best practice.

A subject matter expert (SME) audit for GHG demonstrated that responsibilities for reporting of GHG emissions were clearly assigned and written procedures existed relating to GHG emissions reporting. GHG emissions reporting were completed for BTS/SCP/WREP Azerbaijan in accordance with BP group guidance. GHG reporting calculation was modified in 2009 in order to include vehicles GHG emissions

19

Note: these are treated separately from environmental monitoring, which is detailed elsewhere in this report.


55

Audit/ Review


Biorestora-tion subject matter audit including compliance


To verify that the bio-restoration programme complies with the applicable ESIAs and ESAPs approved by the regulator and/or lender agencies and AzSPU procedures

A subject matter expert (SME) audit on biorestoration demonstrated that bio-restoration and related activities are being conducted in a diligent and thorough manner. However in some sections of the pipeline route, notably Gobustan, restoration efforts are continuing.

Regular Environmen-tal Inspections

BTC Regular Environmental Inspections of IPA1, PSA2, Block Valves

Weekly and monthly environmental inspections were carried out at all AGIs throughout 2010. No major issued were identified, and all minor issues are closed out as soon as practicable on an ongoing basis.

Internal Social Audit

Exports PU E&S Advisor, Social Specialists from Tur Social Teams

Community Liaison, Infrastructure, Services and Safety Management Plan (ESAP)

No non-compliances were identified. There were a number of positive observations and some areas for improvements and recommendations to address identified gaps with respect to action tracking system, training updates, complaints resolution timeframes, KPIs etc.

11.1.2 Georgia

Environmental inspections and internal audits continued to be carried out at AGIs and along the ROW. A full summary of significant internal reviews and audits is given in Table 11.2.

Table 11.2: Summary of Internal Reviews/Audits, Georgia, 2009

Audit/ Review


Operations EMS Health Check Audit

Auditors from AzSPU assets (other than Geo Pipelines)

Status of BTC/SCP readiness for ISO 14001 re-certification: August 2009

No major gaps were identified with respect to EMS documentation and its implementation at sites. The audit team concluded that BTC/SCP Operation’s EMS was well prepared for ISO14001 Re-certification audit that later took place in October 2009. Audit actions were uploaded and tracked through the Tr@ction system.

Ecological Compliance Audit


Assess compliance status of BTC/SCP against applicable ESIA and ESAP ecological requirements: August 2009

The compliance status of BTC/SCP ecological management against ESIA and ESAP requirements was reviewed. Out of total 55 ecological checklist items 37 were compliant and 10 were not applicable. Audit actions addressing non-compliances were uploaded and tracked through the Tr@ction system.


56

Audit/ Review


Subject Matter Audit: Atmospheric Emissions


Subject Matter Audit: Atmospheric Emissions: August 2009

A subject matter expert audit for air emissions demonstrated that Air emission monitoring both at source and ambient was conducted by qualified and competent personnel on a timely manner and all records, including calibration were available. Significant progress has been made since previous internal air emission subject matter audit (April 2008). The majority of previous findings were closed. However, no MOC was placed, nor did an ESAP revision take place in relation to non compliant NOx concentrations in the pump turbine stack emissions. It is to be noted that the pump turbines are designed and capable of meeting compliance requirements when they work on SoLoNox mode. Audit actions were uploaded and tracked through the Tr@ction system.

Regular Environmental Inspections

BTC Regular Environmental Inspections of PSG1 & 2; Area 80; Camps, ROW

Regular environmental inspections were carried out at all AGIs and camps throughout 2009. Identified issued were tracked through inspection checklists, site Environmental Action plans and action tracking system tools on ongoing basis.


Exports PU E&S Advisor, Social Specialists from Azerbaijan and Turkey Social Teams

Community Liaison, Infrastructure, Services and Safety Management Plan (ESAP)

No non-compliances were identified. There were a number of positive observations and some findings and recommendations to address identified gaps with respect to resource management, procedure updates, etc.

11.1.3 Turkey

Internal monitoring takes place as necessary on a daily basis or through theme audits and reviews. In some cases the review might result in actions and recommendations for implementation.

The significant internal reviews conducted in Turkey during this reporting period are summarised in Table 11.3.

Table 11.3: Summary of Internal Reviews/Audits, Turkey, 2009

Audit/ Review

Auditor Auditee Scope Findings and/or Recommendations

Day to day field inspection and monitoring of reinstatement activities

BTC Co. Reinstate-ment Contractor

Monitoring of the reinstate-ment works on a daily basis by BTC Co. E&CSR teams

The reinstatement contractor was monitored by BTC Co.’s E&CSR staff (two) on full time basis. All complaints successfully resolved in Lot A and Lot B villages as planned in the scope with the support of BTC Co. teams. No open items remained from Lot A and Lot B construction phase.

Management of additional land needs during Operations

BTC Co. BIL and Botaş/DSA

Temporary and permanent land acquisition

BTC Co. CSR team directly managed the monitoring of additional land needs during Operations such as BVT30 incident, BTCX 1.2 expansion works, security road for CMT, rental payments to camp sites, land for PT2 flood permanent mitigation measures, etc. No open items from additional land acquisition activities left in 2009.


57

Audit/ Review


CIP and RDI Technical Monitoring

BTC Co. CIP and RDI Implemen-ting Partners (IPs)

CIP and RDI activities

BTC Co. CSR team and external consultants conducted several site visits to monitor projects and provide technical input to IPs and local organisations.

In total 26 site visits were organised. Site reports were produced after each site visit and shared with the relevant IP. The actions are being followed up on a monthly basis with each IP.


(April 2009)

BTC Co. Azerbaijan and Georgia Social teams

BTC Co. & BIL Social teams in Turkey

Community Liaison, Safety, Infrastructure and Services Plan (BTC ESAP) and Community Relations Programme (BIL Plan)

An internal social audit was conducted for the BTC Operations in Turkey which included documentation review, site visits, followed by interviews with BTC Co. and BIL personnel. The audit results were generally positive.

CIP and RDI Financial Audits

BTC Co. CIP implemen-ting partners (grantees)

Financial compliance to grant agreements

In addition to quarterly reviews of financial reports submitted by the implementing partners (IPs), BTC Co. Finance team together with an external finance consultant conducted audits on all CIP projects.

Similar audits will also be conducted on RDI projects in 2010. The audit results will be completed in 2010-Q1.

Municipality Emergency Response Capacity Audit

BTC Co. & BIL HS&ER and Social teams

Ardahan (close to PT1) and Erzincan (close to PT3) Municipa-lities

Compliance to Emergency Response Plan

The aim of this review was to identify the capacity of local authorities in responding hydrocarbon fires along the BTC route. This was done as part of the needs assessment survey undertaken for one of the RDI projects which was under development in 2009.

Waste Management BPEO (Best Practicable Environmental Option) Audits

BTC Co. & BIL Environmental teams

Antakya, Erzurum, Erzincan, Trabzon, Bayburt Municipa-lities (Landfills)

Adana, Mersin, Kayseri, Kars Cement Factories

Continuous Improvement (ESAP)

The overall objective of the study was to determine the Best Practicable Environmental Option (BPEO) for the management of wastes arising from BTC operations in Turkey.

Waste Water Feasibility Study Audits

BTC Co. & BIL Environmental teams

Adana, Erzincan, Kayseri, Osmaniye, Sivas Municipa-lities (WWTPs)

Compliance with ESAP

5 Municipal WWTPs along the pipeline route were audited to determine their ability to take project wastes in emergency situations. Facilities at Adana, Kayseri, Osmaniye and Sivas were found to be suitable.


58

Audit/ Review


Pre-IEC Audits and Environmental Compliance Reviews – All facilities and the ROW; May-June 2009

BTC Co. BIL Compliance with ESAP and ESIA

Level I and II non-conformances were identified during the pre-IEC Audit and Environmental Compliance Review. Three were identified (one each at IPT1, PT3 and PT4). All related with non-compliant waste water discharges.

EIP Internal Evaluation – ongoing throughout the year

EIP Consultants

EIP implemen-ting partners (grantees)

Additionally (Environmental Investment)

Scientific monitoring of Project ecological impacts was recommended. Gaps in H&S driving training and office safety equipment were identified and corrective actions were taken.

Table 11.4: Audits Conducted by BIL

Audit/Review Auditee Scope Findings and/or Recommendations

Quarry Sites Audit Canogullari Quarry (Adana) Compliance with ESAP

The facility was found as compliant.

Environmental Compliance Audit of Contractors

SESMeke Ceyhan OSR Base Compliance with ESAP

Findings were recorded and will be followed up during next visits/audits.


ITEMSAN – General Services (inc. cleaning)


The new contractor was found to be compliant.


Polat Yemek – Catering Company




Yıldız Nakliyat – Hazardous Waste Carrier



Waste Management BPEO (Best Practicable Environmental Option) Audits

Antakya, Erzurum, Erzincan, Trabzon, Bayburt Municipality Landfills

Adana, Mersin, Kayseri, Kars Cement Factories

Continuous Improvement (ESAP)

Same as above.

Waste Water Feasibility Study Audits

Adana, Erzincan, Kayseri, Osmaniye, Sivas Municipality WWTPs


Same as above.

11.2 EXTERNAL REVIEWS

11.2.1 ISO 14001 Certification

BTC retained certification against the international environmental management system standard ISO 14001 following to re-certification audit in October 2009. Audit ended successfully with no system findings in Azerbaijan and Georgia. The certification body was Moody International.

11.2.2 Independent Environmental Consultants

The 11th post-financial audit of Independent Environmental Consultant (IEC), acting on behalf of BTC Lenders, was accomplished in Azerbaijan, Georgia and Turkey in June 2009. The objectives of the Audit were to assess project performance against BTC project environmental and social commitments, report any non-compliances, assign a appropriate levels of importance (Level I, II or III, with III being the most significant), and verify closure of BTC’s responses to non-compliances identified in previous monitoring visits.


59

The audit did not identify any new non-compliance in either Azerbaijan or Georgia. Previous issues associated with non-hazardous waste disposal were considered closed as a result of the successful start-up of the BP Georgia EU-compliant non-hazardous waste landfill in May 2009. However, an earlier Level I non-compliance related to NOx stack emissions was retained.

There was one Level 1 non compliance raised in Turkey related to E&S Management Organization and Resources.

Appendix 3 contains details of the non-compliances along with a summary of actions taken to resolve the issue. Full reports are given on www.bp.com/caspian.

11.2.3 Social and Resettlement Action Plan (SRAP) Panel

The RAP Completion Audit, undertaken by the SRAP Panel, assessed the effectiveness of RAP measures for restoring or enhancing project affected households’ standards of living and livelihood up until the end of 2009.

The Audit utilized both quantitative and qualitative approaches to gather data and assess household standards of living. Particular attention was paid to assessing the impact of RAP interventions on the circumstances of vulnerable households.

The focus of the audit was as follows:

Households that comprise full-time residents of project affected villages and that, as owners or users of BTC affected land, are substantially reliant on agriculture for their income and livelihood;

Households that experienced permanent loss of use of land for above ground installations (AGIs);

Vulnerable households.

The Completion Audit had four principle components:

NGO verification of compensation entitlements delivery, grievance redress and dispute resolution through consultation;

Quantitative household survey;

Qualitative survey (stakeholder and key informant interviews);

SRAP Panel assessment of unresolved grievances, court cases and disputes.

The RAP Completion Audit Quantitative survey was completed in February 2009 and the Qualitative survey completed in September 2009. The final assessment report is awaited from SRAP panel.

The results of the SRAP monitoring actions closure from previous visits are given in Appendix 4.

11.2.4 Azerbaijan Social Review Committee

Azerbaijan SPU continued its cooperation with Azerbaijan Social Review Commission (ASRC), an independent external monitoring group dedicated to provide assurance, advice to BP's social performance in Azerbaijan. In May 2009 BP hosted a BP-ASRC session which discussed a number of issues related to our performance. The session was followed by third Azerbaijan Social Review Committee (ASRC) report to BP containing a number of observations and recommendations. This report and the Company's response were posted on the public website - www.bp.com/caspian. The Commission’s mandate has been extended for another 2 years to cover 2010-11.

http://www.bp.com/caspian


60

11.2.5 Polaris

An external audit of BTC’s Oil Spill Response readiness in Azerbaijan and Georgia was conducted by Polaris in October 2009. The key findings of the audit were:

BTC has maintained and improved its oil spill readiness capability relative to the findings of the 2007 OSR audit;

The Corporate commitment to spill readiness is evident in the project’s policies and actions;

BTC has maintained an action tracking programme and implemented a number of recommendations and lessons arising from earlier audits and previous exercises;

SEACOR teams have maintained a high level of response preparedness;

IMT and OSR contractors are nearly 100% comprised of nationals;

OSR equipment has been added at bases;

The Azerbaijan response programme is in a transition phase, with a strong response capability that is expected to improve further as the new team at PSA 2 gains experience.

Further details can be found in Appendix 5 which contains a summary of Polaris audit findings and key recommendations.

11.2.6 Turkey External Reviews/Audits

Table 11.5: Audits Conducted by External Parties

Audit/ Review

Auditor Auditee Scope Findings and or recommendations

RAP Close Out Audit

SRAP Panel Botaş/DSA and BIL

Land acquisition/ livelihood restoration, reinstatement, operations phase community relations management, etc.

See Appendix 4.3.

Employment Standards Audit; May-June 2009

Ministry of Labor and Social Security

BIL and its sub-contractors at all facilities along the p/l route

Health and safety conditions of the facilities, social security and tax issues

Ministry of Labor and Social Security audited BIL activities in all PTs, IPT1 and CMT for 20 days between May and June 2009.

Audit results were submitted to BIL after completion of each site by the Ministry inspectors. In summary main findings were:

All BIL and contractor personnel have social security and their taxes are paid in line with local regulations.

Some of the project documents (plans and procedures) are in English but implementation documents were translated into Turkish. Plans, procedures should also be translated in local language.

Camps used for construction are now used for operations. Conditions of the camp site should be improved.


61

Audit/ Review

Auditor Auditee Scope Findings and or recommendations

There were also some recommendations to improve the H&S conditions of the work environment which are already in the scope of BIL.

Environmental Review; Feb 2009

Adana Provincial Directorate of MoEF

BIL Compliance with MARPOL

Information on final status was provided to auditors; no finding recorded.

Environmental Review; March 2009

Erzincan Provincial Directorates of MoEF and State Hydraulic Works

BIL BVT30 activities and status

Information was provided to auditors; no finding recorded.


62

APPENDIX 1

Annex J of the Construction ESAP – Outline of Project Environmental and Social Monitoring Annual Report20

Each annual report will address each of the topics listed below for BTC Co. activities conducted in Azerbaijan, Georgia and Turkey.

1 EXECUTIVE SUMMARY


2.1 SUMMARY OF ANY MATERIAL MODIFICATIONS TO THE AZERBAIJANI, GEORGIAN AND TURKISH ESIAS DURING THE YEAR.

2.2 SUMMARY OF MATERIAL PERMITS ISSUED DURING THE YEAR AND ANY APPLICABLE CONDITIONS.

2.3 UPDATE ON STATUS OF PROJECT STATE SPECIFIC REQUIREMENTS FOR FURTHER WORK UNDER THE ESIAS OR PERMITS.

3 CHANGES

3.1 DESCRIPTION OF ANY CHANGES TO AN ESIA DURING THE PERIOD TO REFLECT A CLASS I, II OR III CHANGE.

3.2 SUMMARY OF THE TYPE OF CLASS I CHANGES IMPLEMENTED DURING THE PERIOD, OR A CONFIRMATION OF NO SUCH CHANGE.

3.3 LIST OF ALL CLASS II CHANGES NOTIFIED DURING THE PERIOD, OR CONFIRMATION OF NO SUCH CHANGES.

3.4 SUMMARY OF ALL CLASS III CHANGES DURING THE PERIOD, OR CONFIRMATION OF NO SUCH CHANGES.

3.5 UPDATE ON CONSTRUCTION STATUS IN A CHANGE AREA INCLUDING DESCRIPTION OF ANY IMPACTS OR MITIGATION MEASURES.

3.6 DESCRIPTION OF ANY MATERIAL AMENDMENT, SUPPLEMENT, REPLACEMENT OR MATERIAL MODIFICATION TO AN ESIA, THIS ESAP, THE RAP, THE ESMS, OR ANY OSRP.


4.1 SUMMARY OF ANY NOTICES OF NON-COMPLIANCE, REMEDIAL ACTION, ANY FINES OR PENALTIES PAID AND FINAL DISPOSITION OF ANY REGULATORY PROCEEDINGS.

4.2 SUMMARY OF AIR EMISSIONS.

4.3 SUMMARY OF ENVIRONMENTAL DISCHARGES.

4.4 STATEMENT INDICATING WHETHER BTC CO. AND ITS AGENTS HAVE COMPLIED IN THE DEVELOPMENT, CONSTRUCTION AND OPERATION OF THE BTC PROJECT WITH THIS ESAP, APPLICABLE ENVIRONMENTAL LAWS AND APPLICABLE LENDER ENVIRONMENTAL AND SOCIAL POLICIES AND GUIDELINES IN ALL MATERIAL RESPECTS AND SUMMARY OF ANY (I) MATERIAL NON-COMPLIANCE AND THE STEPS BEING TAKEN TO REMEDY IT AND (II) MATERIAL MODIFICATIONS OF ESIAS, PLANS OR PROGRAMMES MATERIALLY IN CONTRAVENTION OF THE OPERATIONAL POLICIES AND DIRECTIVES LISTED IN THIS ESAP.

4.5 UPDATE ON SIGNIFICANT CHANGES IN APPLICABLE LAW, IF ANY.


5.1 SUMMARY OF OSRPS COMPLETED, UPDATED OR AMENDED DURING YEAR (AS DESCRIBED IN THIS ESAP).

5.2 SPILL SUMMARIES (AZERBAIJAN, GEORGIA AND TURKEY).

5.3 SPILL RESPONSE AND REMEDIATION SUMMARIES.

5.4 SUMMARY OF MATERIAL MODIFICATIONS TO THE OSRPS DESCRIBED IN THIS ESAP.

6 CIP AND EIP PROGRAMMING

6.1 SUMMARY OF PROGRAMMING FOR THE PAST YEAR.

6.1 COMPARISON OF ACTUAL TOTAL EXPENDITURES AND BUDGETED TOTAL EXPENDITURES.

6.3 DESCRIPTION OF EXPECTED BUDGET AND PROGRAMMING FOR THE COMING YEAR.

7 ENVIRONMENTAL AND SOCIAL MONITORING PROGRAMME

7.1 SUMMARY OF ESMS MONITORING COMMITMENTS COMPLETED DURING THE YEAR, INCLUDING SUMMARY OF RESULTS, COMPARISON OF ENVIRONMENTAL PERFORMANCE TO APPLICABLE ENVIRONMENTAL STANDARDS AND SUMMARY OF PERFORMANCE AGAINST KPIS.

7.2 SUMMARY OF ENVIRONMENTAL AND SOCIAL TRAINING.


8.1 UPDATE OF ONGOING COMMUNICATION WITH EXTERNAL STAKEHOLDERS.

8.2 UPDATE OF COMMUNITY LIAISON ACTIVITIES.

9 SUMMARY OF RESULTS OF RAP MONITORING


10.1 DAYS AWAY FROM WORK CASES.

10.2 INJURIES.

10.3 FATALITIES.

11 AUDITS

11.1 SUMMARY OF THE RESULTS OF BTC CO. AND BOTAŞ’S INTERNAL ENVIRONMENTAL AND SOCIAL AUDIT PROGRAMMES.

20

Following completion of construction, the annual report will not cover items that are relevant only to construction. In addition, if matters are covered in the Operations ESAP that are not reflected in the contents for the annual report, this Annex will be amended as appropriate to cover these matters.


63

Annex H of the Operations ESAP – Outline of Project Environmental and Social Monitoring Annual Report

Each annual report will address each of the topics listed below for BTC activities conducted in Azerbaijan, Georgia and Turkey.

1 EXECUTIVE SUMMARY


2.1 SUMMARY OF ANY MATERIAL MODIFICATIONS TO THE AZERBAIJANI, GEORGIAN AND TURKISH ESIAS DURING THE YEAR.

2.2 SUMMARY OF MATERIAL PERMITS ISSUED DURING THE YEAR AND ANY APPLICABLE CONDITIONS.

2.3 UPDATE ON STATUS OF PROJECT STATE SPECIFIC REQUIREMENTS FOR FURTHER WORK UNDER THE ESIAS OR PERMITS.

3 CHANGES

3.1 DESCRIPTION OF ANY CHANGES TO AN ESIA DURING THE PERIOD TO REFLECT A CLASS I, II OR III CHANGE.

3.2 SUMMARY OF THE TYPE OF CLASS I CHANGES IMPLEMENTED DURING THE PERIOD, OR A CONFIRMATION OF NO SUCH CHANGE.

3.3 LIST OF ALL CLASS II CHANGES NOTIFIED DURING THE PERIOD, OR CONFIRMATION OF NO SUCH CHANGES.

3.4 SUMMARY OF ALL CLASS III CHANGES DURING THE PERIOD, OR CONFIRMATION OF NO SUCH CHANGES.

3.5 DESCRIPTION OF ANY MATERIAL AMENDMENT, SUPPLEMENT, REPLACEMENT OR MATERIAL MODIFICATION TO AN ESIA, THIS ESAP, THE RAP, THE ESMS, OR ANY OSRP.


4.1 SUMMARY OF ANY NOTICES OF NON-COMPLIANCE, REMEDIAL ACTION, ANY FINES OR PENALTIES PAID AND FINAL DISPOSITION OF ANY REGULATORY PROCEEDINGS.

4.2 SUMMARY OF AIR EMISSIONS.

4.3 SUMMARY OF ENVIRONMENTAL DISCHARGES.

4.4 STATEMENT INDICATING WHETHER BTC CO. AND ITS AGENTS HAVE COMPLIED IN THE DEVELOPMENT, CONSTRUCTION AND OPERATION OF THE BTC PROJECT WITH THIS ESAP, APPLICABLE ENVIRONMENTAL LAWS AND APPLICABLE LENDER ENVIRONMENTAL AND SOCIAL POLICIES AND GUIDELINES IN ALL MATERIAL RESPECTS AND SUMMARY OF ANY (I) MATERIAL NON-COMPLIANCE AND THE STEPS BEING TAKEN TO REMEDY IT AND (II) MATERIAL MODIFICATIONS OF ESIAS, PLANS OR PROGRAMMES MATERIALLY IN CONTRAVENTION OF THE OPERATIONAL POLICIES AND DIRECTIVES LISTED IN THIS ESAP.

4.5 UPDATE ON SIGNIFICANT CHANGES IN APPLICABLE LAW, IF ANY.


5.1 SUMMARY OF OSRPS COMPLETED, UPDATED OR AMENDED DURING YEAR (AS DESCRIBED IN THIS ESAP).

5.2 SPILL SUMMARIES (AZERBAIJAN, GEORGIA AND TURKEY).

5.3 SPILL RESPONSE AND REMEDIATION SUMMARIES.

5.4 SUMMARY OF MATERIAL MODIFICATIONS TO THE OSRPS DESCRIBED IN THIS ESAP.

6 ADDITIONALITY PROGRAMMING

6.1 SUMMARY OF PROGRAMMING FOR THE PAST YEAR.

6.2 COMPARISON OF ACTUAL TOTAL EXPENDITURES AND BUDGETED TOTAL EXPENDITURES.

6.3 DESCRIPTION OF EXPECTED BUDGET AND PROGRAMMING FOR THE COMING YEAR.

7 ENVIRONMENTAL AND SOCIAL MONITORING PROGRAMME

7.1 SUMMARY OF ESMS MONITORING COMMITMENTS COMPLETED DURING THE YEAR, INCLUDING SUMMARY OF RESULTS, COMPARISON OF ENVIRONMENTAL PERFORMANCE TO APPLICABLE ENVIRONMENTAL STANDARDS AND SUMMARY OF PERFORMANCE AGAINST KPIS.

7.2 SUMMARY OF ENVIRONMENTAL AND SOCIAL TRAINING.


8.1 UPDATE OF ONGOING COMMUNICATION WITH EXTERNAL STAKEHOLDERS.

8.2 UPDATE OF COMMUNITY LIAISON ACTIVITIES.

9 SUMMARY OF RESULTS OF RAP MONITORING (AS APPLICABLE)


10.1 DAYS AWAY FROM WORK CASES.

10.2 INJURIES.

10.3 FATALITIES.

11 AUDITS

11.1 SUMMARY OF THE RESULTS OF BTC CO. AND BIL’S INTERNAL ENVIRONMENTAL AND SOCIAL AUDIT PROGRAMMES.


64

APPENDIX 2: ENVIRONMENTAL MONITORING RESULTS

APPENDIX 2.1: AZERBAIJAN

Please read this section in conjunction with the commentary in Section 4.2.1.

Appendix 2.1a – Ambient Air Quality

Pollutant Standard Units Averaging Period

NO2 40 (Annual average will reduce by 2 µg/m3 every year,

to reach 40 µg/m3 by 1 January 2010)

µg/m3 Annual mean

SO2 20 µg/m3 Annual mean

Benzene 5 (Annual average will reduce by 1 µg/m3 every year

from 2006, to reach 5 µg/m3 by 1 January 2010)

µg/m3 Annual mean

PM10 20 (30 on 1 January 2005, reducing every 12 months thereafter by equal annual percentages to reach 20 by 1 January 2010)

µg/m3 Annual mean

PSA2:

ID Jan-Feb 2009

Mar-Apr 2009

May-Jun 2009

Jul-Aug 2009

Sep-Oct

2009

Nov-Dec 2009

Annual Mean

Pollutant Units

PSA 2 AQ 3p 8 6 5 7 10 8 6.3 NO2 µg/m3

PSA 2 AQ 5p 8 6 5 7 10 8 6.3 NO2 µg/m3

PSA 2 AQ 6p 10 10 9 11 12 10 10.3 NO2 µg/m3

PSA 2 AQ 7p 9 6 7 7 5 8 7 NO2 µg/m3

PSA 2 AQ 8p 16 8 8 10 11 10 10.5 NO2 µg/m3

ID Jan-Feb 2009

Mar-Apr 2009

May-Jun 2009

Jul-Aug 2009

Sep-Oct 2009

Nov-Dec 2009

Annual Mean

Pollutant Units

PSA 2 AQ 3p 1 3 6 6 1 1 3 SO2 µg/m3

PSA 2 AQ 5p 1 5 11 6 4 1 4.6 SO2 µg/m3

PSA 2 AQ 6p <1 8 6 9 1 1 5 SO2 µg/m3

PSA 2 AQ 7p <1 5 15 6 30 6 12.4 SO2 µg/m3

PSA 2 AQ 8p 2 3 6 11 2 2 4.3 SO2 µg/m3

ID Jan-Feb 2009

Mar-Apr 2009

May-Jun 2009

Jul-Aug 2009

Sep-Oct

2009

Nov-Dec 2009

Annual Mean

Pollutant Units

PSA 2 AQ 3p 2.7 2.22 0.85 2.9 1.5 1.845 2 Benzene µg/m3

PSA 2 AQ 5p 2.4 1.06 0.8 1.65 2.15 3.455 1.92 Benzene µg/m3

PSA 2 AQ 6p 2.95 1 0.95 2.5 0.9 2.115 1.74 Benzene µg/m3



IPA1:

Date Sep-Oct 2009 Units

Pollutant SOx NOx

IPA 1 AQ 1p 3 15 µg/m3

IPA 1 AQ 2p 3 12 µg/m3


65

Appendix 2.1b – Stack Emissions Monitoring

Emission Stream Sources Pollutant Standard Units

MOL Turbine

NOx 70-75 at 15% O2, dry mg/Nm3

CO N/A mg/Nm3

SO2 35 mg/Nm3

PM10 5 mg/Nm3

Generators

NOx 2000 mg/Nm3

CO 650 mg/Nm3

SO2 1700 mg/Nm3

PM10 130 mg/Nm3

PSA 2 / IPA-1:

Equipment Date tested

Load (MW, Speed in % and Tem°C)

Fuel Mean stack gas concentrations Mass Emissions

NOx CO SO2 PM NOx CO SO2 PM

mg/Nm3, corrected to 15% O2 g/h

PSA-2 Turbine 1

21.05.09 91.6% speed

Gas 107 358 0 5 818 11589 0.0 47

PSA-2 Turbine 2

01.12.09 88.8% speed

Gas 103 2041 0 5 4817 95394 0.0 289

PSA-2 Turbine 3

01.12.09 90% speed Gas 109 1685 0 5 5143 79266 0.0 291

PSA-2 Turbine 4

03.12.09 88.7% speed

Gas 101 2233 0 5 4711 104046 0.0 288

PSA-2 Generator A

30.09.09 40.5% kWth Diesel 464 198 7 50 2683 1146 44 358

PSA-2 Generator B

30.11.09 43.3% kWth Diesel 492 236 0 50 2636 1269 0.0 332

PSA-2 Generator C

30.09.09 47.5% kWth Diesel 487 191 22 50 2766 10857 128 351

PSA-2 WBH 01.10.09 65% °C Diesel 200 1182 12 50 78 465 4 21

IPA-1 Generator A

29.09.09 52.3% kWth Diesel 1107 78 0 50 1551 110 0.0 86

IPA-1 Generator B

29.09.09 53.1% kWth Diesel 1078 89 35 50 1403 116 45 80

NOTE: Figures in red indicate non-compliance with project standards

Appendix 2.1c – Environmental Noise

Standard Units Period

PSA2 & IPA1 & Block Valves

55 dB (A) Daytime

45 dB (A) Night-time

PSA2:

ID Readings Units Date Duration Comments

PSA 2 NM 1p 40 dB (A) Sep-2009 5 min daytime

PSA 2 NM 2p 42 dB (A) Sep-2009 5 min daytime

IPA-1:


NM 1p 36 dB (A) Sep-2009 5 min daytime



Block Valves:


AB-4 NM 1p 35 dB(A) Nov-2009 5 min daytime


AB-10 NM 1p 46 dB (A) Nov-2009 5 min daytime

AB-11 NM 1p 40 dB(A) Nov-2009 5min daytime





66

Appendix 2.1d – Effluent Discharge Monitoring Programme

Parameter Standard Units Parameter Standard Units

Total coliform bacteria (per 100ml) <400 MPN/100ml Ag 0.5 mg/l

pH 6-9 As 0.1 mg/l

Total residual chlorine 0.2 mg/l Cd 0.1 mg/l

BOD 25 mg/l Cr (total) 0.5 mg/l

COD 125 mg/l Cu 0.5 mg/l

Total suspended solids 35 mg/l Fe 3.5 mg/l

Ammonia NH4 10 mg/l Pb 0.1 mg/l

Total Nitrogen 15 mg/l Hg 0.01 mg/l

Phenols 0.5 mg/l Ni 0.5 mg/l

Total Phosphorus 2.0 mg/l Se 0.1 mg/l

Sulphides 1.0 mg/l Zn 2.0 mg/l

Oil and grease 10 mg/l

PSA-2 (Sample Location – PSA-2 Retention Pond)

Parameter Units Month, 2009

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Total coliform bacteria per 100ml 56.7 16 58.7 157 274 97.7 170 552.5 1234 233.3 164 81.3

pH - 7.54 7.47 7.53 7.41 7.23 7.23 7.26 7.32 7.48 7.38 7.36 7.42

Total residual chlorine mg/l <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 0.02 0.03 0.03 0.025

COD mg/l 23.7 32 14.6 17.7 42 56.8 50 16 23.4 18.3 31 20

Total suspended solids mg/l 2 0.03 2.7 1.5 2.3 0 0 1.6 1.2 1 3.5 2.5

Ammonia NH4 mg/l 0.04 1 0.08 0.11 0.33 0.6 0.3 0.4 0.32 0.22 0.2 0.27

Total Nitrogen mg/l 8 16 14.5 2 3 1.45 - - 4.8 8.63 9.5 11.9

Turbidity FNU 4.46 0.42 1.15 1.01 2.11 10.1 1.55 4.43 1.5 0.55 2.5 4.75

Conductivity mS/cm 1.7 1.7 1.76 1.76 1.7 1.7 1.8 1.97 2.18 1.68 1.08 1.36


67

Appendix 2.1e – Groundwater & Surface Water Monitoring Programme

Groundwater Monitoring – Karayazi & Around PSA2

Date of sampling May 2009

Parameter Unit

Kar M1 Kar M2 Kar M3 Kar M5 Kar M6 Kar M7 Kar M8 Kar M10

PSA-2

Aran Yaldili

pH -

no w

ate

r

6.8 7.2 7.3

no w

ate

r

no w

ate

r

7.2 7 8.6 9.1

Temperature °C 15.8 16.7 18.8 13.4 17.4 25.7 25.5

Conductivity mS/cm 4.47 3.06 9.35 1.82 11.1 1.97 0.52

THC µg/L <20 <20 <20 <20 <20 <20 <20

PAH µg/L <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

BTEX µg/L <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 <0.02

TSS mg/L 1310 310 51 80 233 5.2 4.4

Date of sampling November 2009

Parameter Unit

Kar M1 Kar M2 Kar M3 Kar M5 Kar M6 Kar M7 Kar M8 Kar M10

PSA-2

Aran Yaldili

pH -

No w

ate

r

6.9 7.2 7.3

No w

ate

r

No w

ate

r

7.1 7 8.7 9.3

Temperature °C 16 15 16 15 15 19 18

Conductivity mS/cm 4.62 3.4 8.1 2.52 11.3 1.95 0.52

THC µg/L <20 <20 <20 <20 <20 <20 <20

PAH µg/L 0.01 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 BTEX µg/L <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 TSS mg/L 175 340 20 110 110 <2 <2

Surface Water Monitoring PSA2

Date of sampling May-09 Nov-09

Parameter Unit SW1 SW2 SW1 SW2

Total coliform bacteria (per 100ml) per 100ml 1.6x103 2x10

3 2.4x10

3 3.5x10

3

pH - 7.8 7.7 8 8

BOD mg/l <0.5 <0.5 0.7 0.6

COD mg/l 6.8 5.9 10 0.9

Total suspended solids mg/l 82 12 9.3 2

Ammonia NH4 mg/l <0.01 <0.01 0.02 0.03

Total Nitrogen mg/l 0.62 1.1 0.75 1.5

Total Phosphorus mg/l <0.03 0.06 0.03 0.5

TPH µg/L <20 <20 <20 <20

PAHs (sum of 4) µg/L <0.01 <0.01 0.01 0.01

Benzene µg/L <0.02 <0.02 <0.05 <0.05 Toluene µg/L <0.02 <0.02 <0.05 <0.05 Ethylbenzene µg/L <0.02 <0.02 <0.05 <0.05 o-Xylenes µg/L <0.02 <0.02 <0.05 <0.05

Surface Water Monitoring IPA1

Date of sampling May-09 Nov-09

Parameter Unit SW1 SW2 SW1 SW2

Total coliform bacteria (per 100ml) per 100ml 2.7x103 2.3x10

3 4.6x10

3 1.2x10

4

pH - 7.3 7.8 7.9 8.4

BOD mg/l 0.9 67 2 1.4

COD mg/l 13.8 17.9 8.4 10

Total suspended solids mg/l 9.7 116 15 <2

Ammonia NH4 mg/l 0.02 0.02 0.03 0.03

Total Nitrogen mg/l 1.1 0.89 0.89 1

Total Phosphorus mg/l 0.06 0.05 0.06 0.03

TPH µg/L 26 23 <20 25

PAHs (sum of 4) µg/L 0.01 <0.01 <0.01 0.01

Benzene µg/L <0.020 <0.020 <0.05 <0.05 Toluene µg/L <0.020 <0.020 <0.05 <0.05 Ethylbenzene µg/L <0.020 <0.020 <0.05 <0.05 o-Xylenes µg/L <0.020 <0.020 <0.05 <0.05

NOTE: SW1 - Upstream sampling point; SW2 - Downstream sampling point


68

Appendix 2.1f – Waste

BTC Waste Volumes: Summary – 2009

Unit Value

Main Waste Streams

Oily Solid Waste (oily rags, filters, absorbents, polyethylene)

tonne 11.4

Oily water m3 141

Oil and diesel (used) m3 0

Sewage wastes (raw) m3 1753

Sewage sludge m3 Included into sewage water

Contaminated cans and drums tonnes 6.4

Antifreeze m3 Included into chemicals

Chemicals tonnes 16

Wax tonnes 7

Fluorescent tubes tonne 0.3

Insulation material tonne Included into non-recyclable domestic waste

Construction waste m3

Included into non-recyclable domestic waste

Pig discs tonne

12.2

Aerosol cans m3 0.1

Non-recyclable domestic wastes tonne 57.4

Paper tonne 1

Wood tonne 1.3

Metal tonne 7.8


69

APPENDIX 2.2: GEORGIA

Please read this section in conjunction with the commentary in Section 4.2.2.


Pollutant Standard Units Averaging Period

NO2 40 (Annual average will reduce by 2 µg/m3 every year,

to reach 40 µg/m3 by 1 January 2010)

µg/m3 Annual mean

SO2 20* µg/m3 Annual mean

Benzene 5 (Annual average will reduce by 1 µg/m3 every year

from 2006, to reach 5 µg/m3 by 1 January 2010)

µg/m3 Annual mean

PM10 20 (30 on 1 January 2005, reducing every 12 months thereafter by equal annual percentages to reach 20 by 1 January 2010)**

µg/m3 Annual mean

* For the protection of vegetation and ecosystems

** No PM 10 was measured in 2009 due to the system running on natural gas

NOx results

ID Feb - 2009

Apr-2009

Jun-2009

July-2009

Aug-2009

Oct-2009

Dec-2009

Pollutant

Units

PSG 1-1 0.45 0.26 0.54 0.54 0.29 0.36 0.44 NOx µg/m3

PSG 1-2 0.55 0.22 0.35 0.35 0.36 0.42 0.48 NOx µg/m3

PSG 1-3 0.45 0.31 N/A N/A 0.28 0.35 0.44 NOx µg/m3

PSG 1-4 0.53 N/A 0.41 0.41 0.31 0.43 0.51 NOx µg/m3

PSG 1-5 0.54 N/A 0.49 0.49 0.34 0.57 0.33 NOx µg/m3

PSG 2-1 0.4 0.11 0.05 0.05 0.07 0.12 0.11 NOx µg/m3

PSG 2-2 0.24 0.08 0.12 0.12 0.05 0.1 0.12 NOx µg/m3

PSG 2-3 0.1 0.07 0.05 0.05 0.04 0.11 0.1 NOx µg/m3

PSG 2-4 0.26 0.21 0.15 0.15 0.09 * 0.07 NOx µg/m3

PSG 2-5 0.18 0.11 0.06 0.06 0.11 0.17 0.11 NOx µg/m3

SOx results

ID Feb -2009

Apr-2009

Jun-2009

July-2009

Aug-2009

Oct-2009

Dec-2009

Pollutant Units

PSG 1-1 0.32 0.57 1.73 1.73 0.63 0.24 0.14 SOx µg/m3

PSG 1-2 0.38 0.51 0.6 0.6 0.94 0.25 0.12 SOx µg/m3

PSG 1-3 0.46 0.99 N/A N/A 0.8 0.32 0.09 SOx µg/m3

PSG 1-4 0.53 N/A 0.55 0.55 0.69 0.79 0.2 SOx µg/m3

PSG 1-5 6.95 N/A 5.47 5.47 1.33 0.25 0.12 SOx µg/m3

PSG 2-1 0.28 0.29 2.49 2.49 0.25 0.18 0.22 SOx µg/m3

PSG 2-2 0.36 0.29 0.25 0.25 0.41 0.24 0.08 SOx µg/m3

PSG 2-3 0.28 0.27 0.28 0.28 0.41 0.24 0.36 SOx µg/m3

PSG 2-4 0.32 0.25 0.31 0.31 0.33 * 0.09 SOx µg/m3

PSG 2-5 0.31 0.35 0.43 0.43 0.34 0.19 0.31 SOx µg/m3

Benzene results

Benzene Feb - 2009

Apr-2009

Jun-2009

July-2009

Aug-2009

Oct- 2009

Dec-2009

Pollutant Units

PSG 1-1 0.57 0.2 0.66 0.66 0.98 0.49 0.53 Benzene µg/m3

PSG 1-2 0.85 0.4 0.38 0.38 0.58 0.72 0.60 Benzene µg/m3

PSG 1-3 0.50 0.3 0.49 0.49 0.45 0.39 0.65 Benzene µg/m3

PSG 1-4 0.52 0.4 0.37 0.37 0.44 0.50 0.50 Benzene µg/m3

PSG 1-5 0.67 0.4 0.73 0.73 1.61 0.37 0.51 Benzene µg/m3

PSG 2-1 0.27 0.6 0.26 0.26 2.89 0.75 0.31 Benzene µg/m3

PSG 2-2 0.43 0.2 0.53 0.53 4.73 0.35 0.24 Benzene µg/m3

PSG 2-3 0.33 0.2 0.52 0.52 1.46 0.26 0.37 Benzene µg/m3

PSG 2-4 0.28 0.1 0.30 0.30 0.88 0.24 0.41 Benzene µg/m3

PSG 2-5 0.68 0.6 1.12 1.12 0.55 0.18 0.32 Benzene µg/m3

N/A - Tubes displaced by external party

* - Laboratory was not able to analyze the tube due to damage or similar reason


70

Appendix 2.2b – Stack Emissions

Emission Stream Sources Pollutant Standard Units

MOL Turbine

NOx 70-75 at 15% O2, dry mg/Nm3

CO N/A mg/Nm3

SO2 35 mg/Nm3

PM10 5 mg/Nm3

Generators

NOx 2000 mg/Nm3

CO 650 mg/Nm3

SO2 1700 mg/Nm3

PM10 130 mg/Nm3

November-December 2009 and March 2010: Annual monitoring

NOTE: Figures in red indicate non-compliance with project standards

Equipment Date Load

Concentration at ref conditions

NOx CO SO2 PM

mg/m3

PSG 1

MOL Turbine 1 08.03.10 90% 112.76 1534.79 2.05 3.61

MOL Turbine 2 26.06.09 95% 38.87 82.30 0.00 3.98

MOL Turbine 2 08.03.10 90% 118.04 1359.50 0.26 3.66

MOL Turbine 3 09.03.10 90% 115.58 1165.00 2.40 3.42

MOL Turbine 4 09.03.10 90% 122.99 960.16 0.00 3.62

MOL Turbine 5 08.03.10 90% 125.07 799.74 0.00 3.65

Generator 1 23.12.09 441.50 256.30 17.95 37.35

Generator 2 23.12.09 481.34 172.20 19.32 37.26

Generator 3 23.12.09 449.58 200.36 18.19 37.68

WBH 12.03.10 162.68 0.09 66.53 29.16

PSG 2

MOL Turbine 1 16.03.10 92% 119.55 1296.77 0.14 3.50

MOL Turbine 2 16.03.10 91% 114.32 1142.52 0.00 3.55

MOL Turbine 3 17.03.10 92% 108.32 1525.64 2.81 3.51

MOL Turbine 4 15.03.10 92% 118.80 609.96 0.00 3.51

MOL Turbine 5 15.03.10 92% 134.08 534.08 0.00 3.72

Generator 1 22.12.09 432.54 248.32 18.55 38.23

Generator 2 22.12.09 461.07 212.24 16.94 37.83

Generator 3 22.12.09 437.04 200.65 19.12 37.77

WBH 18.03.10 170.70 2.74 57.30 29.81


71

Appendix 2.2c – Environmental Noise

Standard Units Period

PSGs 55 dB (A) Daytime

45 dB (A) Night-time

2009-Q1 – PSG 1, Area 72, PSG 1 Camp, PSG 2, PSG 2 Camp, Area 80, Akhaltsikhe Camp, Tsalka OSRB, Borjomi OSRB

Monitoring point GPS Coordinate

Date and Time

Noise Readings in dBA

Background noise

PSG 1/Area 72 NM 1 8512350 19.02.09 Max 52.7

Birds 4589284 10:55 Average 50.9

PSG 1/Area 72 NM 2 8512277 19.02.09 Max 54.2

Birds 4589632 11:25 Average 52.7

PSG1 Camp NM1 8512325 04.03.09 Max 46.7

N/A 4589015 11:15 Average 45.7

PSG 1/Area 72 NM 3 8513467 19.02.09 Max 47.1

Irrigation channel 4590290 12:05 Average 44.3

PSG 2 NM 1 8450375 19.02.09 Max 52.7

Birds. Light wind 4602555 14:25 Average 49.5

PSG 2 NM 2 8450170 19.02.09 Max 52.3 Birds

4602501 14:59 Average 50.1 Light wind

Area 80 NM 1 8319395 20.02.09 Max 45.2

N/A 4610010 13:20 Average 44.3

Area 80 NM 2 8319201 20.02.09 Max 45.1

N/A 4610129 13:50 Average 44.8

PSG2 CAMP NM1 8452711 05.03.09 Average 48.2 Camp generators within

40m. Birds 4600379 12:50 Max 51.3

PSG2 CAMP NM2 8452675 05.03.09 Average 42.5

Birds 4600248 13:25 Max 44.1

PSG2 CAMP NM3 8452657 05.03.09 Average 41.2

Birds 4600181 13:55 Max 43.4

Akhaltsikhe camp NM1 8334644 06.03.09 Average 42.3

People, light vehicle 4613771 14:15 Max 59.2


Birds 4613988 14:35 Max 42.5


Traffic 4613607 15:15 Max 58.2

OSRB1 8368530 09.03.09 Average 50.3

Cars from road 4632354 13:15 Max 51.9

OSRB2 8368529 09.03.09 Average 57.8 River, road traffic,

heavy vehicles 4632251 13:35 Max 69.7

OSRB3 8368465 09.03.09 Average 55.9 River, road traffic,


OSRBNR 8368251 09.03.09 Average 58.2 River, road traffic,


OSRT1 8421025 10.03.09 Average 46.9

Birds 4606632 14:15 Max 49.1

OSRT2 8420964 10.03.09 Average 44.7

Birds 4606641 14:35 Max 45.6

OSRT3 8420925 10.03.09 Average 49.4

Birds 4606586 14:45 Max 50.8

OSRTNR 8420566 10.03.09 Average 51.2

Birds, vehicle 4607965 15:05 Max 61.3


72

2009-Q2 – PSG 1, AREA 72, PSG 1 CAMP, PSG 2, PSG 2 CAMP, AREA 80, AKHALTSIKHE CAMP, TSALKA OSRB, BORJOMI OSRB


Date and Time


Background noise

PSG 1/Area 72 NM 1 8512350 10.05.09 Max 53.7

Birds 4589284 10:25 Average 51.2

PSG 1/Area 72 NM 2 8512277 10.05.09 Max 53.7

Birds 4589632 10:45 Average 52.4

PSG1 Camp NM1 8512325 10.05.09 Max 44.3

Birds.Frogs 4589015 11:25 Average 42.6

PSG 1.Area 72 NM 3 8513467 10.05.09 Max 36.1

N/A 4590290 12:05 Average 35.1

PSG 2 NM 1 8450375 12.05.09 Max 53.2

Rain 4602555 15:30 Average 52.1

PSG 2 NM 2 8450170 12.05.09 Max 52,5

Rain 4602501 16:10 Average 51.9

PSG2 CAMP NM1 8452711 12.05.09 Max 51.5 Camp generators

within 40m. Birds 4600379 16:50 Average 49.2

PSG2 CAMP NM2 8452675 12.05.09 Max 44.4

Birds 4600248 17:10 Average 43.1

PSG2 CAMP NM3 8452657 12.05.09 Max 43.9

Birds 4600181 17:25 Average 41.5

Area 80 NM 1 8319395 14.05.06 Max 46.4

Birds 4610010 10:15 Average 45.1

Area 80 NM 2 8319201 14.05.06 Max 47.8

Birds 4610129 10:35 Average 47.1

Akhaltsikhe camp NM1 8334644 14.05.06 Max 48.2

People, birds 4613771 12:45 Average 45.4


Birds 4613988 13:05 Average 40.7


Traffic 4613607 13:20 Average 54.1

OSRB1 8368530

13.05.09 Max 55.1

birds 4632354 Average 54.4

OSRB2 8368529

13.05.09 Max 49.3

River 4632251 Average 49.1

OSRB3 8368465

13.05.09 Max 49.8

River 4632339 Average 49.4

OSRBNR 8368251

13.05.09 Max 49.6 River, road traffic,

heavy vehicles. 4632817 Average 49.3

OSRT1 8421025

13.05.09 Max 51.2

Birds, people, wind 4606632 Average 45.9

OSRT2 8420964

13.05.09 Max 48.1

Birds, wind 4606641 Average 47.1

OSRT3 8420925

13.05.09 Max 52.2

Birds 4606586 Average 51.1

OSRTNR 8420566

13.05.09 Max 37.2

Birds 4607965 Average 34.3


73

2009-Q3 – PSG 1, AREA 72, PSG 1 CAMP, PSG 2, PSG 2 CAMP, AREA 80, AKHALTSIKHE CAMP, TSALKA OSRB, BORJOMI OSRB


Date and Time


Background noise

PSG 1/Area 72 NM 1 8512350 28.09.09 Max 53.9

Birds 4589284 10:35-10:41 Average 51.7

PSG 1/Area 72 NM 2 8512277 28.09.09 Max 55.7

Birds 4589632 10:56-11:02 Average 53.6

PSG1 Camp NM1 8512325 28.09.09 Max 48.6

Birds/Frogs 4589015 11:25-11.31 Average 44.9

PSG 1/Area 72 NM 3 8513467 28.09.09 Max 36.8

N/A 4590290 11:45-11:51 Average 35.4

PSG 2 NM 1 8450375 28.09.09 Max 55.1

Birds 4602555 14:45 Average 53.3

PSG 2 NM 2 8450170 28.09.09 Max 52,9

Birds 4602501 15:10 Average 52.3

PSG2 CAMP NM1 8452711 28.09.09 Max 49.8 Camp generators

within 40m. Birds 4600379 15:50 Average 49.1

PSG2 CAMP NM2 8452675 28.09.09 Max 44.9

Birds 4600248 16:10 Average 44.2

PSG2 CAMP NM3 8452657 28.09.09 Max 46.9

Birds 4600181 16:25 Average 45.2

Area 80 NM 1 8319395 21.09.09 Max 49.8

Birds 4610010 16:29-16:35 Average 47.6

Area 80 NM 2 8319201 21.09.09 Max 49.3

Birds 4610129 16:45-16:50 Average 47.4


People, birds 4613771 08:35-08:41 Average 45.8


Birds 4613988 08:52-08:58 Average 41.2


Birds 4613607 09:10-09:17 Average 54.8

OSRB1 8368530 22.09.09 Max 54.8

Birds 4632354 13:47-13:53 Average 54.1

OSRB2 8368529 22.09.09 Max 49.7

River 4632251 13:35-13:41 Average 49.3

OSRB3 8368465 22.09.09 Max 49.9

River 4632339 14:02-14:09 Average 49.2

OSRBNR 8368251 22.09.09 Max 50.1 River, road traffic,

heavy vehicles 4632817 14:35-14:40 Average 49.8

OSRT1 8421025 14.09.09 Max 47.7

Birds 4606632 13:48-13:55 Average 45.5

OSRT2 8420964 14.09.09 Max 47.9

Birds, wind 4606641 14:15-14:21 Average 47.1

OSRT3 8420925 14.09.09 Max 52.4

Birds 4606586 14:23-14:29 Average 51.3

OSRTNR 8420566 14.09.09 Max 37.7

Birds 4607965 14:45-14:51 Average 35.6


74

2009-Q4 – PSG 1, AREA 72, PSG 1 CAMP, PSG 2, PSG 2 CAMP, AREA 80, AKHALTSIKHE CAMP, TSALKA OSRB, BORJOMI OSRB AND EDDF


Date and Time


Background noise

PSG 1/Area 72 NM 1 8512350 15.12.09 Max 53.3

Birds 4589284 10:25-10:35 Average 51.1

PSG 1/Area 72 NM 2 8512277 15.12.09 Max 54.9

Birds 4589632 10:47-10:53 Average 52.8

PSG1 Camp NM1 8512325 15.12.09 Max 47.9

Birds/Frogs 4589015 11:20-11.27 Average 45.6

PSG 1/Area 72 NM 3 8513467 15.12.09 Max 37.9

N/A 4590290 11:38-11:44 Average 36.1

PSG 2 NM 1 8450375 16.12.09 Max 49.3

Birds 4602555 09:26-09:31 Average 48.7

PSG 2 NM 2 8450170 16.12.09 Max 45.4

Birds 4602501 09:43-09:47 Average 44.3

PSG2 CAMP NM1 8452711 16.12.09 Max 46.3

Birds 4600379 10:07-10:12 Average 45.0

PSG2 CAMP NM2 8452675 16.12.09 Max 55.3

Birds 4600248 15:11-15:17 Average 53.6

PSG2 CAMP NM3 8452657 16.12.09 Max 52,3

Birds 4600181 15:31-15:36 Average 51.9

Area 80 NM 1 8319395 17.12.09 Max 48.7

N/A 4610010 14:16-14:21 Average 47.9

Area 80 NM 2 8319201 21.09.09 Max 50.8

Birds 4610129 14:35-14:40 Average 49.3


People 4613771 16:42-16:47 Average 46.1


Birds 4613988 17:12-17:17 Average 42.3


People 4613607 17:31-17:37 Average 54.9

OSRB1 8368530 21.11.09 Max 54.2

N/A 4632354 13:22-13:27 Average 53.8

OSRB2 8368529 21.11.09 Max 49.8

River 4632251 13:45-13:50 Average 49.1

OSRB3 8368465 21.11.09 Max 50.1

River 4632339 14:00-14:07 Average 49.7

OSRBNR 8368251 22.09.09 Max 49.7 River, road traffic,

heavy vehicles 4632817 13:01-13:06 Average 49.3

OSRT1 8421025 27.11.09 Max 47.4

N/A 4606632 13:11-13:17 Average 45.1

OSRT2 8420964 27.11.09 Max 48.1

Wind 4606641 13:28-13:34 Average 47.6

OSRT3 8420925 27.11.09 Max 52.1

Birds 4606586 13:43-13:48 Average 51.0

OSRTNR 8420566 27.11.09 Max 37.3

Birds 4607965 14:48-14:52 Average 36.7

EDDF1 8371325 21.11.09 Max 40.1

River 4621123 16:10-16:15 Average 39.4

EDDF2 8371485 21.11.09 Max 35.7

N/A 4620962 16:35-16:40 Average 35.3

EDDF3 8370815 21.11.09 Max 38.3

People 4621309 16:55-17:00 Average 36.4


75

Appendix 2.2d – Effluent

Figures in red show non-compliances with the operations standards

PSG 1

Parameters Stan-dards


Monthly

pH 6-9 8.25 8.7 8.4 8.6 7.87 8.05 8.01 6.77 7.68 6.98 7.65 8.44

COD 125 35 58 33 61 47 7 15 14 17 >3 >3 >3

Oil and grease 10 2 1.4 2.3 1.8 5.6 <1 2.8 3.1 1.6 1.6 1.1 2.1

TSS 35 16 36 16 62 74 44 56 6 42 94 10 20

NH4 10 0.2 0.2 0.46 0.21 0.58 0.16 1.05 0.05 0.22 2.05 0.02 0.1

Sulphide 1 <0.1 <0.1 0.8 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 >0.1 >0.1 >0.1

Coliform <400 8 7 26 33 5400 5400 9200 350 11000 92000 1800 26

Quarterly

BOD 25 6.5 12.6 5.8 5.6 5.8 6.4

Heavy metals 10 <10 <10 <10 <10 >10

As 0.1 <0.01 <0.01 <0.01 <0.01 >0.01

Cd 0.1 <0.01 <0.01 <0.01 <0.01 >0.01

Cr (6) 0.1 0.02 <0.03 <0.03 <0.03 >0.03

Cr total 0.5 0.04 <0.01 <0.01 0.07 0.01

Cu 0.5 <0.01 <0.01 <0.01 <0.01 0.01

Fe 3.5 <0.01 0.1 0.2 <0.01 1.9

Pb 0.1 <0.01 <0.01 <0.01 <0.01 >0.01

Hg 0.01 <0.01 <0.01 <0.01 <0.01 >0.01

Ni 0.5 <0.01 <0.01 0.2 <0.01 >0.01

Se 0.1 <0.01 <0.01 <0.01 <0.01 >0.01

Ag 0.5 <0.01 <0.01 <0.01 <0.01 >0.01

Zn 1 0.12 <0.1 0.6 0.05 >0.01

Phenols 0.5 <0.03 <0.03 <0.02 <0.02 >0.02

Chlorine 0.2

PSG 2

Parameters Standards Apr May Jun Jul Aug Sep Oct Nov

Monthly

pH 6-9 8.4 7.45 7.9 7.87 8.3 7.65 8.3 7.9

COD 125 22 26 <3 <3 14 <3 >3 >3

Oil & grease 10 1.4 4.7 <1 0.9 2 1.2 1.2 1

TSS 35 6 1476 21 24 2 20 22 14

NH4 10 <0.02 0.19 0.09 <0.01 0.09 <0.01 >0.01 >0.01

Sulphide 1 <0.005 <0.1 <0.1 <0.1 <0.1 <0.01 >0.1 >0.1

Coliform <400 14 240 33 79 350 1700 94 920

Quarterly

BOD 25 9.4 0.4 5.4 4.8

Heavy metals 10 <10 <10 <10

As 0.1 <0.01 <0.01 <0.01

Cd 0.1 <0.01 <0.01 <0.01

Cr (6) 0.1 <0.03 <0.03 <0.03

Cr total 0.5 <0.01 <0.01 0.05

Cu 0.5 <0.01 <0.01 <0.01

Fe 3.5 <0.1 0.2 0.1

Pb 0.1 <0.01 <0.01 <0.01

Hg 0.01 <0.01 <0.01 <0.01

Ni 0.5 <0.01 0.4 <0.01

Se 0.1 <0.01 <0.01 <0.01

Ag 0.5 <0.01 <0.01 <0.01

Zn 1 <0.1 0.1 <0.01

Phenols 0.5 <0.03 <0.02 <0.02

Chlorine 0.2

No monitoring conducted in January, February, March and December – retention pond frozen or dry.


76

PSG 1 Camp



pH 6-9 7.15 7.15 7.2 6.9 7.2 7.1 7.79 6.73 7.15 6.53 7.2 7.22

BOD 25 0.16 9.2 0.24 8.2 6.8 5.6 2.9 6.2 5.1 5.6 4.2 8.4

COD 125 <3 13 10 12 13 12 9 38 <3 >3 >3 >3

TSS 35 4 2 2 18 4 2 3 12 14 8 8 4

TDS - 720 753 627 541.2 542.4 726.6 873 276 613.2 847.8 975.6 762.6

NH4 10 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.07 0.02 0.4 >0.01 >0.01

Oil and grease 10 1.5 1.6 4.5 1.4 4.3 <1 2 2.8 1.5 1.5 1.3 1.5

Coliform <400 350 49 280 130 240 1600 49 17 460 920 140 110

PSG 2 Camp



pH 6-9 7.3 7.6 7.5 7.1 7.37 7.21 7.31 6.9 7.58 7.25 7.55 7.65

BOD 25 0.15 10.8 0.18 8.8 6.4 0.8 0.6 5.8 4.9 4.4 4.1 7.8

COD 125 <3 20 20 17 13 <3 4 20 4 >3 >3 >3

TSS 35 2 4 3 8 24 2 3 2 7 4 2 4

TDS - 569 526.8 471 597.6 486 590.4 552.6 496.8 543.6 521.4 487.2 528

NH4 10 <0.01 <0.01 <0.01 <0.01 0.04 <0.01 <0.01 0.01 0.01 0.01 >0.01 >0.01

Oil and grease 10 1 1.9 2 1.8 4.3 <1 0.9 0.9 1.3 1.1 1.4 1

Coliform <400 1600 9200 17 22 14 14 350 1600 >1800 140 1700 27

Akhaltsikhe Camp



pH 6-9 6.85 7 7.05 6.8 7.15 6.97 7.02 6.61 7.08 6.75 7.75 7.05

BOD 25 0.16 11.6 0.26 7.9 7.2 0.9 0.8 5.8 5.4 5 4.25 8.1

COD 125 <3 22 10 14 13 <3 8 26 11 >3 >3 >3

TSS 35 2 2 3 4 14 7 5 2 10 4 2 2

TDS - 1277 1263.6 1192.8 1123.2 880.8 987 777.6 919.2 1124.4 1186.2 303 985.8

NH4 10 <0.01 <0.01 <0.01 <0.01 0.05 <0.01 <0.01 <0.01 0.07 0.07 0.02 0.32

Oil and grease 10 1.9 2.4 4 1.4 2 <1 0.9 1.8 1.4 1.3 1.2 1.4

Coliform <400 2 13 170 <2 170 5 350 220 2 5 70 <2

One-off as consistent with MoE new Technical Regulations – February 2009

Parameters Standards PSG 1 PSG 1 camp

PSG 2 camp

Akhaltsikhe camp

Total Surface Activated Substances (Detergents) 2 0.42 0.37 0.21 0.28

Total Nitrogen 15 25.8 22.6 10.6 11.3

Total Phosphorus 2 5.3 3.7 4 1.6


77

Appendix 2.2e – Ground and Surface Waters

Reports on seasonal rounds of monitoring:

May-June 2009

Location Benzene Toluene Ethylbenzene Xylene Naphthalene TPH

1 µg/l 1 µg/l 1 µg/l 1 µg/l 1 µg/l 10 µg/l

BMW 9 <1 <1 <1 <1 <0.1 <10/<10

BMW 10 <1 <1 <1 <1 <0.1 <10/<10

BMW 11 <1 <1 <1 <1 <0.1 <10/<10

TSW 9 <1 <1 <1 <1 <0.1 <10/<10

TSW 20 <1 <1 <1 <1 <0.1 <10/<10

KTMW 14 <1 <1 <1 <1 <0.1 <10/<10

TMW 7 DRY; included into the rehabilitation programme



KTMW 4 Was damaged and represented hazard to livestock - decommissioned

KTMW 15 DRY; included into the rehabilitation programme

July 2009



BMW 9 <0.2 <0.2 <0.2 <0.5 <1 <0.2

BMW 10 <0.2 <0.2 <0.2 <0.5 <0.2 <10

BMW 11 <0.2 <0.2 <0.2 <0.5 <1 <0.2

TSW 9 <0.2 <0.2 <0.2 <0.5 <1 <0.2

TSW 20 <0.2 <0.2 <0.2 <0.5 <1 <0.2

KTMW 14 <0.2 <0.2 <0.2 <0.5 <1 <0.2





KTMW 15 DRY; included into the rehabilitation programme

August 2009



BMW 9 <0.2 <0.2 <0.2 <0.5 <1 <10

BMW 10 <0.2 <0.2 <0.2 <0.5 <1 <10

BMW 11 <0.2 <0.2 <0.2 <0.5 <1 <10

TSW 9 <0.2 <0.2 <0.2 <0.5 <1 <10

TSW 20 <0.2 <0.2 <0.2 <0.5 <1 <10

KTMW 14 <0.2 <0.2 <0.2 <0.5 <1 <10

TMW 7 DRY; rehabilitation programme initiated




KTMW 15 DRY; rehabilitation programme initiated

September-October 2009



BMW 9 <0.2 <0.2 <0.2 <0.5 <0.3 <10

BMW 10 <0.2 <0.2 <0.2 <0.5 <0.2 <10

BMW 11 <0.2 <0.2 <0.2 <0.5 <0.4 <10

TSW 9 <0.2 <0.2 <0.2 <0.5 <0.2 <10

TSW 20 <0.2 <0.2 <0.2 <0.5 <0.2 <10

KTMW 14 <0.2 <0.2 <0.2 <0.5 <0.2 <10

TMW 7 Rehabilitation works completed; existing well washed and deepened.

However no positive outcome; well remains dry.

TMW 13 Rehabilitation works completed. The new well was drilled up to 20 m

(original well's depth was 16 m). However, no positive outcome; well remains dry

TMW 15 Rehabilitation works completed. The existing well was deepened and washed.

However, no positive outcome; well remains dry

KTMW 15 <0.2 0.41 <0.2 <0.5 <0.2 <10



78

Report for Water supply re-sampling:

Analysis Benzene Toluene Ethyl-benzene

Xylenes Naph-thalene

Fraction C10-C12

Fraction C12-C22

Fraction C22-C30

Fraction C30-C40

Unit µg/l µg/l µg/l µg/l µg/l µg/l µg/l µg/l µg/l

MDL 1 1 1 1 1 10 10 10 10

Vale-WS02-July 04

<1 <1 <1 <1 3664 <10 <10 <10 <10

Vale-WS02-R008-09

<0.2 <0.2 <0.2 <0.5 <0.3 <10 <10 <10 <10

Sakuneti-WS01-July 04

<1 <1 <1 <1 4341 <10 <10 <10 <10

Sakuneti-WS01-R008-09

<0.2 <0.2 <0.2 <0.5 <0.2 <10 <10 <10 <10

Sakire-WS01-July 04

<1 <1 <1 <1 1134 <10 <10 <10 <10

Sakire-WS01-R008-09

<0.2 <0.2 <0.2 <0.5 <0.2 <10 <10 <10 <10

Sadgeri-WS01-July 04

<1 <1 <1 <1 1192 <10 <10 <10 <10

Sadgeri-WS01-R008-09

<0.2 <0.2 <0.2 <0.5 <0.2 <10 <10 <10 <10

Moliti-WS02-July 04

<1 <1 <1 <1 4204 <10 <10 <10 <10

Moliti-WS02-R008-09

<0.2 <0.2 <0.2 <0.5 <0.2 <10 <10 <10 <10

Andeziti-WS01-July 04

<1 <1 <1 <1 1427 36 <10 <10 <10

Andeziti-WS01-R008-09

<0.2 <0.2 <0.2 <0.5 <0.2 <10 <10 <10 <10

Tsikhisjvari-WS03-July 04

<1 <1 <1 <1 1725 <10 <10 <10 <10

Tsikhisjvari-WS03-R008-09

<0.2 <0.2 <0.2 <0.5 <0.2 <10 <10 <10 <10

Appendix 2.2f – Waste

Total Figures, 2009

TYPE OF WASTE (m3) PSG1

(site and camp)

PSG2 (site and

camp)

SES Tsalka

SES Borjomi

BVs SES Rustavi and Tbilisi

Office

Hazardous waste disposed offsite

Oily solids 22.4 25.2 1 0.6 0 2.6

Oily liquids 5.8 60 6.2 0.2 36 2.4

Sewage sludge 350 248 0 0 0 48

Wax 0 0 0 0 0 0

Other 59.8 35.8 0 7.5 2.2 1.4

Non-hazardous waste re-cycled/recovered offsite

Glass (stored) 21 20 0 0 0 0

Plastic (stored) 75 41 17 5.2 0 0

Paper (stored) 70 29 8.4 5 0 12

Metal (stored) 4.2 2.4 0 0.4 0 0

Timber (stored) 2.2 3.4 0 0.3 0 0

Organic Wastes (food wastes) 36 58 0 0 0 0

General 370 454 84 22 0 419


79

APPENDIX 2.3: TURKEY


Air Quality Standards for Ground Level Concentrations (µg/m3)

Parameter Project Standards (Turkey)

Averaging Period

VOCs Benzene: 5 Annual average by 2010. A limit value of 10 µg/m

3 (100%) must be met

on 13 December 2000, reducing on 1 January 2006 and every 12 months thereafter by 1 µg/m

3 to reach 0% (5 µg/m

3) by 1 January 2010.

Oxides of Nitrogen (NOx)

40 Annual mean

Sulphur Dioxide (SO2)

20 24 hour average

NOTE: Figures in red show non-compliance with project standards

Ceyhan Marine Terminal – Averages of 2009 Measurements

No. Monitoring

Date

Average Ambient Concentrations (µg/m3)

SO2 NOx Benzene Toluene Ethyl

Benzene o-xylene

mp- xylene

CMT 1

Jan-A

pr-

July

-Oct

2009 5.21 13.99 1.17 7.00 0.80 0.51 1.95

CMT 2 3.83 13.41 1.01 5.79 0.64 0.55 1.37

CMT 3 23.18 10.62 0.93 1.58 0.47 0.51 1.16

CMT 4 3.08 13.76 0.94 1.56 0.51 0.43 0.87

CMT 5 6.51 16.17 0.92 5.18 0.83 0.68 1.76

CMT 6 5.85 13.64 0.86 3.32 0.55 0.49 1.13

CMT 7 4.37 11.03 0.8 1.65 0.49 0.43 1.13

CMT 8 6.46 12.14 0.74 4.07 0.60 0.57 1.21

CMT 9 9.02 11.65 0.78 2.42 0.60 0.83 2.00

CMT 10 6.35 8.78 1.13 11.51 1.46 1.23 3.77

Appendix 2.3b – Stack Emissions

Stack Emission Standards

Emission stream sources Parameters Project Specified Standard

5 MW Reciprocating engines (gas fired)

(PTs 1, 2, 3 and 4)

NOx

SO2

CO

PM

500 mg/Nm3 (5% Volumetric O2)




Water Heaters (diesel fired)

(Wax Handling Boilers at CMT, IPT1 and IPT2)

NOx

SO2

CO

Soot


1,000 mg/Nm3 (3% Volumetric O2)


2

Water Heaters (gas and LPG fired)

(CMT, PTs 1, 2, 3 and 4)

NOx

SO2

CO

PM





Generators/Fire pumps (diesel fired) (monitored only if the annual run time is < 500 hrs)

NOx

SO2

Soot

CO

PM


1,000 mg/Nm3 (3% Volumetric O2)

2



NOTE: Figures in red show non-compliance with project standards.


80

Stack Emission Monitoring Results for Pump Stations (April 2009)

Parameter

Emission Source

Driver Engines Water Heaters

1 2 3 4 5 1 2 3

Facility: PT1

NOx 161 134 103 102 Was not running during

monitor.

95 95 98

SO2 0 0 0 0 0 0 0

PM 1,76 1,81 1,32 1,01 0,06 0,21 0,17

CO 46 69 51 42 24 57 13

Facility: PT2

NOx 122 104 144 158

Not existing

116 103 110

SO2 0 0 0 0 0 0 0

PM 0,49 0,51 0,25 0,26 0,45 0,52 0,31

CO 44 39 40 49 11 6 6

Facility: PT3

NOx 177 218 192 205 213 105 103 Was not running during

monitor.

SO2 0 0 0 0 0 0 0

PM 0,31 0,32 0,25 0,27 0,27 0,5 0,7

CO 59 29 93 100 108 2 5

Facility: PT4

NOx 274 Was not running during

monitor.

283 264

Not existing

111 113 104

SO2 0 0 0 0 0 0

PM 0,28 0,22 0,34 0,51 0,56 0,63

CO 3 11 23 3 3 1

Stack Emission Monitoring Results for Ceyhan Marine Terminal (April 2009)

Parameter

Emission Source

Parameter

Emission Source

Process Area Wax Handling

Boiler (diesel)

Metering Wax

Handling Boiler

(diesel)

General Facilities

Water Heater 1

(LPG)

General Facilities

Water Heater 2

(LPG)

Housing Compound

Water Heater (LPG)

Process Area

Water Heater (LPG)

NOx 131 108 NOx

Not measured. SO2 0 0 SO2

soot 2 2 PM

CO 4 13 CO

Stack Emission Monitoring Results for Intermediate Pigging and Pressure Reduction Station (April 2009)

Parameter Emission Source

Wax Handling Water Heater Diesel Generator

Facility: IPT1

NOx 105

n/a since runs < 500 hrs/year SO2 0

soot 1.5

CO 12

Facility: IPT2

NOx 58 141

SO2 0 0

soot 1.7 3.7

CO 7 52

PM n/a Not measured.


81

Appendix 2.3c – Aqueous Discharges

Aqueous Discharge Standards

Waste stream sources Parameters Project Specified Standard

Aqueous discharges to surface and marine waters from oily water

separators

All limits 95th percentiles of annual operational hours.

pH 6-9 for fresh water and 5-9 for marine water


Total suspended solids 35 mg/l

Metals

Heavy metals, total 10 mg/l

Cd 0.05 mg/l

Cr total 0.5 mg/l

Cu 0.5 mg/l

Pb 0.5 mg/l

Hg 0.01 mg/l

Ni 0.5 mg/l

Zn 2 mg/l

NH4 10 mg/l

Phenols 0.5 mg/l

Sulphur 1 mg/l

Aqueous discharges to surface waters

from sewage treatment plants

pH 6-9

BOD 25 mg/l

COD 120 mg/l


Total suspended solids 35 mg/l

Chlorine, total residual 0.2 mg/l

Coliform bacteria <400MPN/100ml

NOTE: Figures in red show non-compliance with project standards

Table Notes:

1. When it is stated that there is ‘no discharge’ it means that the water was sampled but not discharged since the final effluent was not compliant with the Project Standards. In this case non-compliant waste water was re-cycled or when the capacity of the plant was exceeded it was disposed of at a Project approved Municipal WWTP. At CMT where there is a construction phase WWTP still in place, the waste water was transferred to this plant for treatment only if it was operating in compliance with Project Standards.

2. When it is stated that there is ‘no flow’ it means that the water could not be sampled since there was no flow at the time of monitoring.

3. As per EEMP, for OWSs, metals, phenols and sulphur will be monitored on a quarterly basis for one year to determine compliance with project standards. If standards are exceeded on these occasions follow-up monitoring will be undertaken as necessary. During 2008 quarterly OWS monitoring, it was seen that there were some exceedances of sulphur; thus quarterly sulphur monitoring continued in 2009.

4. At the MoEF’s request, one round monitoring of OWSs was conducted consistent with Table 11.2 of Turkish Water Pollution Control Regulation. The parameters that fall outside the regular monthly monitoring parameters were analysed in November 2009 which related results are presented on below tables.


82

Sector: Petroleum Industry (Petroleum Filling Facilities and similar)

Parameter Composite Sample – 2 hrs Composite Sample – 24 hrs

COD 400 mg/l 200 mg/l

TSS 60 mg/l 30 mg/l

Oil and grease 40 mg/l 20 mg/l

Hydrocarbons 6 mg/l 8 mg/l

Phenols 2 mg/l 1 mg/l

Total Cyanide (CN‾) 0.5 mg/l 0.2 mg/l

Sulphur (S‾2) 2 mg/l 1 mg/l

pH 6-9 6-9

PT1 Aqueous Discharges Monitoring Results

Jan 09 Feb 09 March 09 April 09 May 09 June 09 July 09 Aug 09 Sep 09 Oct 09 Nov 09 Dec 09

Ops WWTP

pH

No discharge

8.2

No discharge

7.63

No discharge

7.62

No discharge

7.33

No discharge

BOD (mg/l) <4 11 <4 14

COD (mg/l) 32.30 29.3 23.5 32.3

Oil and grease (mg/l) 2.4 <1.5 <1.5 <1.5

TSS (mg/l) 2.8 14.8 1.6 7.2

Total residual chlorine (mg/l) 0.18 0.08 0.12 <0.02

Coliform bacteria 0 4 43 <3

Storm Water Pond (SWP)

pH

No discharge

BOD (mg/l)

COD (mg/l)

Oil and grease (mg/l)

TSS (mg/l)

Total residual chlorine (mg/l)

Coliform bacteria

OWS

pH 6.35 7.08 7.76 7.23 7.22 7.72 6.9 7.59 8.03 8.29 6.33 7.02

Oil and grease (mg/l) < 1.5 <1.5 3.00 <1.5 2.6 <1.5 <1.5 6.8 <1.5 14.6 4.4 1.6

TSS (mg/l) 9.2 9.6 36.7 8.4 13.6 16 9.2 2 24 37 10 3

Sulphur (mg/l) 1.3

n/a since wasn’t in the programme

<1


<1


No flow <1 n/a since wasn’t in

the programme

COD (mg/l) n/a since wasn’t in

the programme

n/a since wasn’t in

the programme


the programme


the programme

1,925

Hydrocarbons (mg/l) 0

Phenol (mg/l) <0.002

Total cyanide (mg/l) <0.002


83



Ops WWTP

pH

No discharge

7.61

No discharge

No discharge

8.07

No discharge

BOD (mg/l) 14 <4

COD (mg/l) 29 23.5

Oil and grease (mg/l) <1.5 <1.5

TSS (mg/l) 17.6 25.6

Total residual chlorine (mg/l) 0.06 0.19

Coliform bacteria 300 4


pH 7.34

No discharge

BOD (mg/l) 6

COD (mg/l) 65.5

Oil and grease (mg/l) 9

TSS (mg/l) 5.6

Total residual chlorine (mg/l) <0.02

Coliform bacteria 0

SWP upstream

pH 7.61 8.57 7.31 6.51 6.87 7.71 8.18 6.9 8.39 8.15 6.77 7.7

BOD (mg/l) <4 <4 <4 <4 <4 <4 <4 <4 <4 4.9 <4 <4

COD (mg/l) <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20 <20

Oil and grease (mg/l) <1.5 <1.5 <1.5 <1.5 4.8 1.8 4.6 9.6 <1.5 6 <1.5 5.6

TSS (mg/l) <1 <1 1.6 145 44.4 8.8 3.2 75.6 <1 4 1.6 <1

Total residual chlorine (mg/l) <0.02 0.02 <0.02 <0.02 0.02 <0.02 0.05 0.13 0.16 0.06 0.04 0.03

Coliform bacteria 0 300 450 <3 1,100 1,100 >1,100 >1,100 1,100 >1,100 >1,100 1,100

SWP downstream

pH 7.85 8.41 7.68 6.51 6.88 7.85 8.42 7.34 8.76 8.59 6.8 7.64

BOD (mg/l) <4 <4 <4 <4 <4 <4 <4 6.3 <4 <4 <4 <4

COD (mg/l) <20 <20 <20 32.3 <20 <20 <20 64.8 <20 <20 <20 <20

Oil and grease (mg/l) 1.8 <1.5 <1.5 <1.5 3 <1.5 2.2 7 1.6 <1.5 <1.5 <1.5

TSS (mg/l) 4.8 1.6 4.4 256 157 4 2.8 64.8 11.6 1.2 1.6 2.4

Total residual chlorine (mg/l) <0.02 0.06 <0.02 <0.02 0.05 <0.02 0.05 0.16 0.16 0.02 0.02 0.03

Coliform bacteria 0 300 60 150 1,100 460 1,100 >1,100 1,100 >1,100 460 1,100

OWS

pH 6.79

No flow

6.71 6.9 8.88 8.58 7.14 8.13 8.76 7.76 7.24

Oil and grease (mg/l) 1.6 <1.5 14 <1.5 2.6 <1.5 <1.5 <1.5 <1.5 2.6

TSS (mg/l) 14 16 37 33.2 4.8 5. 6 13.2 16.4 8.8 12

Sulphur (mg/l) <0.2


<1


<1


<1 <1


COD (mg/l) n/a since

wasn’t in the programme




<20





84



Ops WWTP

pH

No discharge

7.9 7.48 8.51 8.19 8.5

No discharge

8.27

No discharge

BOD (mg/l) <4 <4 <4 9.5 10.1 <4

COD (mg/l) <20 <20 <20 41.1 82.3 26.4

Oil and grease (mg/l) <1.5 <1.5 <1.5 <1.5 <1.5 6

TSS (mg/l) 6 9.6 14.8 18 30.4 6.4

Total residual chlorine (mg/l) 0.03 0.07 0.18 0.06 0.14 0.57

Coliform bacteria 0 <3 3 <3 <3 <3


pH

No discharge

8.2 8.55

No discharge

8.55 7.95

No discharge

BOD (mg/l) <4 <4 16 6

COD (mg/l) 26.4 29.3 99.9 85.2

Oil and grease (mg/l) 3.8 <1.5 <1.5 <1.5

TSS (mg/l) 12.8 21.6 9.2 10.8

Total residual chlorine (mg/l) 0.11 0.3 0.14 0.2

Coliform bacteria <3 <3 <1.5 4

OWS

pH 7.58 7.7 7.3 7.65 8.44 8.96 7.61 7.08 8.28 7.63 8.18 9

Oil and grease (mg/l) 1.8 <1.5 <1.5 <1.5 <1.5 <1.5 2.2 <1.5 <1.5 10.6 9.6 <1.5

TSS (mg/l) 11.2 11.6 11.6 5.2 16.4 2.4 6.8 12.4 18 37 26.8 4.4

Sulphur (mg/l) 2.9


<1


<1


<1 <1







the programme

126.3






Ops WWTP

pH 7.41 7.99 7.8

No discharge

8.21

No discharge

BOD (mg/l) <4 5 <4 0.6

COD (mg/l) <20 29.3 41.1 52.9

Oil and grease (mg/l) 3.2 8 2.4 1.8

TSS (mg/l) 17.2 13.6 30.8 13.5


Coliform bacteria <1.8 <3 <3 <3


85



pH 7.36

No discharge

8.01 8.73

No discharge

8.13 7.51

BOD (mg/l) <4 24.5 11.3 21.2 12

COD (mg/l) <20 79.3 35.2 52.9 52.9

Oil and grease (mg/l) 3 2.6 2.6 2.2 1.5

TSS (mg/l) 15.6 19.2 18.4 13.6 8.4

Total residual chlorine (mg/l) 0.04 0.08 <0.02 0.02 0.18

Coliform bacteria 36 <3 <3 <3 <3

OWS

pH 7.69 7.69 8.1 8 8.96 8.45 8.79

No flow

9.74 8.83 7.46 8.72

Oil and grease (mg/l) <1.5 30.2 13.6 1.6 7 16.6 <1.5 1.8 9.6 <1.5 <1.5

TSS (mg/l) 5.2 4.8 9.2 29.2 14 31.6 32 6.8 10.8 13.2 6.4

Sulphur (mg/l) <0.2


<1


<1


<1 <1







the programme

23.5




IPT1 Aqueous Discharges Monitoring Results


OWS

pH

No flow

7.14 6.75 6.71 7.1 7.61 7.12 7.41 7.15 7.99 6.68 6.9

Oil and grease (mg/l) 1.5 1.5 3 3.2 1.5 1.5 1.5 2 3.8 2.4 1.5

TSS (mg/l) <1 <1 <1 9.6 <1 3.6 4.4 4.4 <1 6 3.6

Sulphur (mg/l)


<1


<1


<1 3.2






the programme

<20




IPT2 Aqueous Discharges Monitoring Results


OWS

pH

No discharge

8.3 No

discharge

6.32

No discharge

No discharge

6.98 8.08 6.57 No

discharge Oil and grease (mg/l) 2.2 2.6 2.2 3.4 3.4

TSS (mg/l) 30 4.8 10.4 8.8 4

Sulphur (mg/l) <1



<1 <1





41.1





86

CMT Aqueous Discharges Monitoring Results


Ops WWTP

pH 8.67 8.33 8.08 7.77 7.57 7.88 7.5 7.97 8 7.6 8.41 7.74

BOD (mg/l) <4 <4 7.5 13 15 16.5 5.2 22.4 <4 6 <4.0 <4

COD (mg/l) 34 <20 52.9 70.5 61.7 76.4 49.9 73.4 23.5 41.1 <20.0 <20

Oil and grease (mg/l) <1.5 <1.5 <1.5 <1.5 <1.5 <1.5 5.6 <1.5 <1.5 4.6 3 <1.5

TSS (mg/l) 4.8 2.4 10.4 30.8 26.8 16 4.4 4.8 1.6 5.2 10 8

Total residual chlorine (mg/l) 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.07 0.2 0.2 0.2 0.2

Coliform bacteria <400 <400 <400 <400 <400 <400 <400 <400 <400 <400 <400 <3

Construction WWTP

pH 8.22 8.26 8.21 7.91 7.57 7.4 7.65 7.79 7.97 8 7.82 8.08

BOD (mg/l) <4 <4 <4 <4 <4 <4 <4 <4 4 <4 <4.0 <4

COD (mg/l) <20 <20 <20 47 <20 <20 <23.5 <20 <20 32.3 <20.0 <20

Oil and grease (mg/l) <1.5 <1.5 2.2 <1.5 1.8 6 <1.5 <1.5 2 6.8 <1.5 <1.5

TSS (mg/l) 5 4.8 3.6 1.2 <1.0 <1 <1 2 <1 <1 <1.0 2.4

Total residual chlorine (mg/l) 0.2 0.19 0.2 0.2 0.2 0.2 0.2 0.03 0.1 0.2 0.2 0.2

Coliform bacteria <400 3 3 <400 <400 <400 <400 <400 <400 <400 <400 <3


pH

No discharge

8.65

No flow

8.9

No discharge

8.91

No discharge

8.9

No discharge

BOD (mg/l) 5.5 7.6 10.3 10.6

COD (mg/l) 35.2 70.5 76.4 44.1

Oil and grease (mg/l) 1.5 <1.5 <1.5 8.4

TSS (mg/l) 14 29 34.4 19.2


Coliform bacteria 43 <400 <400 <400

SWP upstream

pH 8.22 8.16 7.6 8.14 7.42 8.1 7.75 8.83

No flow

8.05 8.01

BOD (mg/l) <4 <4 <4 <4 13.5 5.4 4.7 5.5 <4.0 <4

COD (mg/l) <20 <20 <20 <20 76.4 <20 52.9 44.1 <20.0 <20

Oil and grease (mg/l) 1.8 <1.5 <1.5 <1.5 <1.5 <1.4 <1.5 <1.5 1.6 <1.5

TSS (mg/l) 35.6 1.2 3.6 14.4 740 94 8 13 3.2 4

Total residual chlorine (mg/l) 0.2 0.02 0.03 0.08 0.02 0.02 0.04 0.04 0.06 0.02

Coliform bacteria 1,100 240 460 460 460 <400 1,100 <400 <400 93


87


SWP downstream

pH 8.44 8.17 8.02 8.03 7.5 8.59 8.18

No flow

8.08 7.95

BOD (mg/l) 6.2 <4 <4 <4 7.6 13.5 15.1 <4.0 4.7

COD (mg/l) 48.3 29.3 <20 26.4 70.5 59.7 44.1 <20.0 <20

Oil and grease (mg/l) 2.2 <1.5 <1.5 <1.5 <1.5 3.4 <1.5 <1.5 <1.5

TSS (mg/l) 20.4 4 6.4 18.4 29 111.6 17.2 13.3 16

Total residual chlorine (mg/l) 0.2 0.02 0.02 0.07 0.02 0.06 0.02 0.05 0.06

Coliform bacteria <400 1,100 <400 460 1,100 1,100 1,100 >1,100 460

OWS 1&2 (office and housing compounds)

pH 7.77 8.15 8.02 7.2 7.8 8.81 8.9

No flow

7.33

No flow

Oil and grease (mg/l) <1.5 <1.5 <1.5 <1.5 <1.5 31 <1.5 <1.5

TSS (mg/l) 18.4 3.6 1.20 8.8 52.8 14 29.5 2

Sulphur (mg/l) 0.7


<1


<1 <1


the programme



<20




OWS 3 (process area)

pH 7.73

No flow

No flow

6.9

No flow

7.25

No flow

Oil and grease (mg/l) <1.5 <1.5 <1.5

TSS (mg/l) 2 7.6 <1.0

Sulphur (mg/l) 0.7



4


the programme

A20




OWS 4 (tank farm)

pH 7.7 7.15 7.7 7.36 6.92

No flow

7.06

No flow

6.84

No flow

Oil and grease (mg/l) 2 <1.5 <1.5 <1.5 3.2 <1.5 <1.5

TSS (mg/l) 3.2 1.2 1 4.8 4.8 <1 1.6

Sulphur (mg/l) 0.5


<1


<1 3.6


the programme



26.4





88


OWS 5 (metering area)

pH 7.62 7.65 7.81 7.98 6.85 7.7 8.1

No flow

7.65 8.37

Oil and grease (mg/l) 6 <1.5 <1.5 <1.5 4.6 5.2 5.4 <1.5 <1.5

TSS (mg/l) 3.2 2 1 1.2 8 3.2 2 1.2 <1

Sulphur (mg/l) 0.7


<1


<1 3.2



the programme



<20




OWS 6 (jetty 1)

pH No

discharge No flow

7.07 6.81

No flow

6.65

No flow

Oil and grease (mg/l) 4.8 5.6 <1.5

TSS (mg/l) 18.4 4.8 6.4

Sulphur (mg/l) 0.7


<1


3.2


the programme


<20




OWS 7 (jetty 2)

pH No

discharge

No flow

6.6

No flow

6.8

No flow

Oil and grease (mg/l) 5.8 <1.5

TSS (mg/l) 9.6 2.8

Sulphur (mg/l) 1.1


No flow

2.4


the programme

<20





89

Appendix 2.3d – Waste

Total Waste Volumes, 2009

All figures are in kg Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total

PT1&IPT2

Hazardous waste disposed offsite 0 0 0 0 0 0 0 0 0 0 0 0 0

Domestic waste disposed offsite 1,813 0 950 4,012 0 1,150 1,970 1,650 720 2,050 1,500 1,178 1,813

Waste water disposed in 3rd party WWTP 15,000 15,000 30,000 30,000 15,000 30,000 23,000 30,000 30,000 30,000 15,000 10,000 15,000

Non-hazardous waste re-cycled 1,085 0 770 1,815 0 1,056 2,485 670 725 1,325 1,150 1,000 1,085

Non-hazardous waste re-used 800 600 925 610 245 665 650 660 505 640 340 567 800

PT2

Hazardous waste disposed offsite 0 0 0 0 4,350 0 0 0 0 0 0 0 0

Domestic waste disposed offsite 3,100 0 1,300 4,110 1,700 1,400 2,400 1,500 1,300 1,800 1,300 3,000 3,100

Waste water disposed in 3rd party WWTP 20,000 10,000 10,000 10,000 0 20,000 30,000 20,000 10,000 10,000 10,000 20,000 20,000

Non-hazardous waste re-cycled 1,900 0 850 550 950 750 1,500 385 320 1,300 420 1,050 1,900

Non-hazardous waste re-used 1,030 785 1,085 1,091 1,060 855 970 860 655 810 746 780 1,030

PT3


Domestic waste disposed offsite 1,300 1,200 1,300 2,900 0 700 2,150 620 500 1,500 1,200 1,450 1,300

Waste water disposed in 3rd party WWTP 20,000 0 10,000 10,000 10,000 10,000 10,000 10,000 0 65,000 10,000 10,000 20,000

Non-hazardous waste re-cycled 2,300 2,250 1,900 10,500 2,775 12,300 3,050 1,800 1,500 2,600 500 2,650 2,300

Non-hazardous waste re-used 1,100 660 850 1,050 750 1,100 1,000 800 700 840 360 650 1,100

PT4


Domestic waste disposed offsite 500 1,250 1,250 2,550 0 2,750 2,500 1,200 0 1,500 900 1,700 500

Waste water disposed in 3rd party WWTP 0 30,000 15,000 17,000 20,000 0 40,000 32,000 20,000 40,000 0 20,000 0

Non-hazardous waste re-cycled 0 1,823 845 1,392 0 1,153 1,641 0 0 1,835 892 0 0

Non-hazardous waste re-used 820 950 810 1,040 1,295 1,705 1,030 940 780 600 750 1,000 820

IPT1


Domestic waste disposed offsite 1,400 1,650 1,450 1,250 2,100 2,950 1,600 950 1,000 2,850 0 2,300 1,400


Non-hazardous waste re-cycled 0 0 993 2,259 320 1,143 0 630 610 0 580 890 0

Non-hazardous waste re-used 3,124 2,671 2,424 480 2,905 3,555 3,054 2,278 1,623 2,014 1,667 1,959 3,124

CMT


Domestic waste disposed offsite 6,425 6,715 8,008 4,715 5,025 10,070 5,584 6,076 6,404 8,107 6,806 6,392 6,425


Non-hazardous waste re-cycled 3,410 1,073 992 1,940 4,264 1,751 1,560 1,180 1,040 1,085 3,800 1,860 3,410

Non-hazardous waste re-used 7,071 7,633 3,685 18,675 6,400 5,954 5,364 5,205 5,930 4,248 3,340 5,114 7,071


90

TOTAL 2009 (in tonnes)

Hazardous waste disposed offsite 10.71

Domestic waste disposed offsite 170.65

Waste water disposed in 3rd

party WWTP 6,454.00

Non-hazardous waste re-cycled 107.14

Non-hazardous waste re-used (solid&liquid) 145.89

Incineration % for solid waste disposed offsite 2.5

Landfill % for solid waste disposed offsite 39.3

Re-cycle % for solid waste disposed offsite 24.7

Re-use % for solid waste disposed offsite 33.6

APPENDIX 2.4: GHG EMISSIONS

GHG Emissions in 2009 (in kilotonnes)

GHG Azerbaijan Georgia Sangachal Turkey Total

January 4.7 20.08 2.60 20.60 47.98

February 5.55 20.04 2.73 23.50 51.82

March 6.37 20.14 3.16 30.02 59.69

April 6.72 24.29 2.30 28.30 61.61

May 6.42 20.81 3.13 34.08 64.44

June 9.56 21.14 2.95 31.95 65.6

July 15.61 25.33 3.00 29.56 73.5

August 7.86 21.08 2.86 32.48 64.28

September 9.26 21.06 3.06 27.73 61.11

October 8.05 17.84 3.23 28.19 57.31

November 7.04 21.25 3.22 26.23 57.74

December 6.44 16.67 3 23.3 49.41

0

10

20

30

40

50

60

70

80

Janu

ary

Febru

ary

Mar

chApr

il

May

June

July

Aug

ust

Sep

tem

ber

Octobe

r

Nove

mbe

r

Dece

mbe

r

Turkey

Sangachal

Georgia

Azerbaijan


91

APPENDIX 3: CLOSE OUT STATUS OF ACTIONS RELATED TO NON-COMPLIANCES RAISED THROUGH IEC MONITORING

Appendix 3 contains BTC Co.’s response and progress towards implementing and effectively closing out the non-compliances raised by IEC. Items that remain open are reported in the BTC E&S Reports until they have been closed. Items that have been closed do not appear in subsequent reports. In adopting this approach, the Project aims to provide the transparency and assurance that measures are being taken to ensure follow-up and close out of all actions to address the non-compliances.

APPENDIX 3A – AZERBAIJAN ACTION STATUS AGAINST AUDIT NON-COMPLIANCES AND RECOMMENDATIONS

Ref. No.

Date of

finding

Category Description of Finding Level of Non- Compliance

Recommendation for Improvement Action Taken Closure Status

2.4.1 June 2009

Monitoring Stack emissions for NOx and CO noncompliant

with ESAP

I Prepare an MOC that justifies not relocating the sampling ports on the diesel generator stacks.

Should BTC choose to modify the emissions standards with an MOC process, the IEC expects that the change would be a Level 3 and that there would be substantial documentations as to the appropriateness of the change (repeat recommendation).

MOC was prepared that justifies not relocating the sampling ports on diesel generator stacks. Routine stack emissions monitoring was carried out at all three of the PSA2 generators and at both of the IPA1 generators and all PSA2 turbines in 2009, by use of existing sampling ports as per US EPA recommended location (i.e. 2 stack diameters downstream and ½ a stack diameter up stream).

All of the stacks were sampled for NOx, CO, NO2, and PM10. This successfully concludes annual stack emissions monitoring required by the ESAP.

All of the generators at PSA2 and IPA1 were found to be in full compliance with all parameters. Emissions from PSA2 turbines indicated elevated levels of NOx compared to ESAP standard and CO (no ESAP standard specified).

As indicated in the BTC Azerbaijan ESIA standards for NOx is 125mg/m

3 and turbines are designed to

meet this standard. Monitoring results of 2008 and 2009 demonstrated that ESAP standard of 75mg/m

3

is not appropriate and should be replaced with ESIA standard.

MOC for changing ESAP standard for NOx was prepared.


92

APPENDIX 3B – GEORGIA ACTION STATUS AGAINST AUDIT NON-COMPLIANCES AND RECOMMENDATIONS

Ref. No.

Date of finding


Recommendation for Improvement Action Taken Closure Status

3.4.1 June 2009

Emis-sions

Manage-ment

Stack emissions for NOx non-compliant with ESAP commitments

I Stack emission testing is ongoing, but an MOC is needed to close out the schedule 21 commitment for modifying the sampling ports for the diesel generator ports and an MOC is needed to justify NOx levels. Emission testing still needs to be done for CTU.

The following actions had been taken to address the recommendations for improvement:

The MOCs had been prepared for submission to Lenders approval for keeping the sample ports at the current locations on generators stacks.

The MOC had been prepared for submission to Lenders approval for justifying NOx stack emissions monitoring standards for MoL turbines.

CTU stack sample ports had been modified to make them suitable for stack emissions monitoring.

Ongoing


93

APPENDIX 3C – TURKEY ACTION STATUS AGAINST AUDIT NON-COMPLIANCES AND RECOMMENDATIONS

Ref. No. Date of finding


Recommendation for Improvement

Action Taken Closure Status

4.2.2 June 2009

E&S Management Organization and Resources

The BIL E&S team is fully operational but still is limited by a number of key vacancies. In particular, the environmental supervisor position at the CMT remains open since June 2008 and the Health and Safety Manager position has been recently vacated. IEC notes that the Environmental Manager is currently covering for these two positions.

Rec. IEC recommends BIL take immediate steps to fill them, particularly the Environmental Supervisor at the CMT.

H&S Manager position was filled in. Two Environmental Supervisor positions are vacant as of end of 2009.

OPEN

4.2.2 June 2009

E&S Management Organization and Resources

IEC observes that BIL has taken steps to provide full time PCR coverage in the field, with the exception of Area 3 (IPT1 & PT3) that is being covered by the PCR supervisor.

Level I Back to back coverage of PCR personnel in Area 3 (IPT1 & PT3) should be provided as soon as possible.

As soon as BIL PCR Department is authorized to recruit new PCREs, appointments will be made to stations where back to back coverage is needed.

OPEN

4.3.2 June 2009

Environmental Tracking and Performance

IEC noted a significant improvement in the management of environmental data associated with BIL operations.

Rec. IEC requests additional clarification from BIL as to how corrective actions raised by BTC through the action logger are being addressed in the BIMS.

Use of preventive corrective action request (PCAR) was started for Level II & III NCRs raised by BTC Co. BIL Environmental team has worked on a new action tracking system (ECO – Environmental Compliance Observation Card System). Level I NCRs and recommendations raised by BTC Co. will be inserted into this new system. The system will be shared with IEC during 2010audit.

OPEN

4.4.2 June 2009

Construction Camps

IEC raised concerns in June 2007 and 2008 about camp due diligence and reinstatement and the final status of construction camps across the Project. Based on review of material provided in the June 2009 visit, IEC is satisfied that reinstatement of construction camps has been completed according to EIA and ESAP standards, with the exception of Kars and Hanak Camps (see below).

Rec. IEC requests that BTC provide a sign-off to these camp closure reports with their verification that all previously identified concerns have been addressed closed in relation to relevant ESAP commitments.

BTC Co. has started to carry out a desktop legal and technical review in 2009 and is planning to define a position with respect to due diligence of construction camps.

OPEN

4.4.2 June 2009

Construction Camps

An MOC regarding the ongoing operation of construction camps at fixed facilities, until at least 2011, has been approved, and IEC notes that BTC has spent additional funds for camp maintenance.

Rec. As noted in the June 2008 report, IEC requested that BTC consider the following: • plans and procedures for compliance to project standards with respect to operation of camp potable water supplies and WWTPs (CMT currently only in operation). CWAAs are being addressed as part of project enhancements;

An MOC which will reflect current plans and future uncertainties is planned to be issued in 2010.

OPEN


94





• control of erosion and implementation of reinstatement plans for construction camps at pump stations and the CMT as part of the MOC for continued use; • establishment of formal decommissioning plans, including a final date and a due diligence procedure for site closure. IEC response – no information provided; • by the time of the next operations audit in June 2010, IEC requests that BTC provide additional indication as to whether the construction camps will be closed and reinstated by 2011, or that an additional modification to the MOC will be required.

4.4.2 June 2009

Construction Camps

In June 2008, IEC noted that although, Kars Camp has been transferred from the Project to the Governorship of Kars and Hanak Camp to the Governorship of Ardahan, there may have been non-Project use after conclusion of BTC usage. IEC raised concerns about discrepancies regarding damage, soil pollution, wastewater, chemical waste, and trash.

Rec. After the June 2009 visit, IEC continues to request further clarification and due diligence regarding the final status of these two camps.

BTC Co. has started to carry out a desktop legal and technical review in 2009 and is planning to define a position with respect to due diligence of construction camps.

OPEN

4.4.4 June 2009

Aggregate and Excess Material Management

Monitoring of reinstatement success should continue at the PT3 dumpsites, in particular DS1, taking into consideration that the sites are located in or next to an environmentally sensitive area (ESA 19), as designated in the Environmental Impact Assessment. IEC was informed by BTC that the DS1 access road will be reinstated by the ROW remediation work contractor by autumn 2009.

Rec. Access road to DS1 was reinstated in 2009. ESA 19 was monitored in 2007 by BTC Co. ESA 19 monitoring locations were added to BIL’s long term ecological monitoring programme as well as other locations and ESA 19 was monitored in 2009. BIL will continue to monitor ESA 19 as part of this programme.

CLOSED

4.4.4 June 2009

Aggregate and Excess Material Management

Since Botaş has now signed off on the Yeniyol Dump site, the Project should make a final decision on whether reinstatement is considered to be successful at this location, in consideration of ESAP commitments. IEC awaits additional information and clarification in this regard.

Rec. Reinstatement of Yeniyol Dump site was deemed acceptable and the site is anticipated to recover over time. No further action is considered.

CLOSED


95





4.5.4 June 2009

Non-Hazardous and Hazardous Waste

IEC remains concerned that the permanent CWAA facility at CMT is not yet operational despite being fully completed in March 2008. In June 2008, IEC was informed that this site was to be operational by September 2008; in June 2009, no progress in this regard is evident.

Rec. IEC recommends that BTC and BIL finalize any outstanding punch list items affecting final completion. BIL should also provide reasons as to why operation permits have not been obtained.

CWAA punch list items were completed in 2009; use of CWAA was started and permit process commenced by end 2009 by BIL.

CLOSED

4.5.4 June 2009


Despite observations of good operating standards at construction camp CWAA’s during audits, IEC notes that little progress has been made to finalize the construction and implementation of permanent CWAAs at fixed facilities.

Rec. IEC understands that a decision regarding these facilities will be made in 2009-Q3 and awaits further information in this regard.

BIL and BTC Co. have jointly prioritised the CWAAs to be built at the operations sites of acilities. Since the existing CWAAs are compliant degradation level will dictate the timing of construction of the operations sites CWAAs.

OPEN

4.5.4 June 2009


IEC notes that chemical storage areas at fixed facilities are nearing completion, but that outstanding punch list items remain unresolved.

Rec. IEC hopes that these punch list items can be quickly resolved and that these facilities become operational as soon as possible. In addition to environmental considerations, a health and safety review should also be undertaken to evaluate fire and worker safety considerations.

Chemical Storage Areas were completed in 2009.

CLOSED

4.5.4 June 2009


IEC observed that wastes originating from the construction phase or waste construction materials are still being stored on-site at construction camps and that BIL has not taken action to remove these wastes, as they originate from Botaş. IEC also observed waste stored at PT2 that is over one year old, despite a pending insurance claim.

Rec. IEC recommends that the project take actions to catalogue and remove this waste to a proper disposal site, rather than leaving it onsite the construction camp CWAAs at fixed facilities.

Materials handed over from the construction phase are legally accepted as public domain. A committee in BIL will soon be established to classify these materials as reusables and wastes. The materials that are defined as waste by the Committee will be disposed of as per the WMP. The waste generated form the flood at PT2 is scheduled to be sent to Izaydas in Feb 2010.

OPEN

4.5.4 June 2009


During the June 2008 audit, IEC visited the Protegol disposal site near Kars Camp. The site was not visited in June 2009.

Rec. N/A N/A N/A

4.5.7 June 2009

Wastewater Management

IEC notes that Project WWTP discharges to storm water ponds (treatment performance) are consistently non-compliant and that BTC has an intention to implement WWTP enhancements to ensure full legal compliance of WWTPs at fixed facilities subject to confirmation based on an on-going feasibility analysis.

Rec. IEC welcomes this initiative to address a long-standing problem and requests that the feasibility analysis underway include an implementation plan and budget and a definite date for construction and operation.

Construction of new WWTPs started at PT1 and 3 and will be completed in 2010. Engineering of PT2 and 4 will be carried out in 2010.

OPEN


96





4.5.7 June 2009

Wastewater Management

BTC has undertaken a third-party review of OWS performance across the project that indicated a variety of considerations, including new performance enhancements and improved maintenance. In some cases, some of the OWS could not be located (e.g. PT1).

Rec. IEC recommends that BTC de-velop an implementation plan to address these issues particular-ly those relating to consistency of maintenance operations across all fixed facilities.

A phased implementation plan was developed by BTC Co. and BIL.

OPEN

4.6.2 June 2009

Pollution Prevention and Environmental Monitoring

IEC notes that steps have been taken to deal with the legal issues regarding water heater and generator stacks at IPTs and CMT and notes that BIL has committed to target implementation by 2009-Q3.

Rec. IEC has noted previously that this issue is not relevant to ESAP compliance, but rather legal compliance with Turkish regulations and requests that this issue be dealt with promptly as it was raised in the June 2008 audit visit.

The stack extensions of wax handling boilers and IPT2 generator were realized by BIL. MoEF identified some stacks as non-compliant as per Turkish Regulation for the Control of Air Pollution Originating from Industrial Establishments (RCAPOIE); the stacks with supposedly non-compliant heights are the generators and fire pumps at facilities. BTC Co. and BIL disagree with MoEF’s approach since they interpret the regulation as these units are exempt from permitting due to their emergency purposes or low thermal power input. MoEF requested from BIL to submit a report that would be prepared by an aca-demic; thus an agreement with a university was done and the review of those units has started. Once the report is finalized; will be issued to MoEF as an attachment to air emission permit application folder.

OPEN

4.6.2 June 2009


IEC notes that BTEX in air is measured as a parameter at the CMT, but that there are no project standards, international standards or limits imposed by Turkish regulations. Higher annual BTEX levels compared to 2007 annual average values at CMT are reported by BTC in the annual report, but IEC can only find that there is a project standard for Benzene levels (5 μg/m3). Furthermore, BTEX should be reported as ppb, not μg/m3.

Rec. IEC requests that the project clarify how BTEX levels are measured in accordance to a project specific standard and the relevance of these measurements, given no standard currently exists. BTC informed IEC that there are several international health guidelines/standards for BTEX compounds and that a comparison with these standards will be considered.

BTC Co. initiated a review in 2009 covering whole year’s monitoring results which will be finalized in 2010.

OPEN

4.6.2 June 2009


IEC was informed that as per the “Noise Regulation” of Ministry of Labor and Social Security, occupational noise monitoring is required and being performed by BIL site HSE and H&S engineers. This information was not available during the 2009 visit and will be reviewed as part of the 2010 audit visit.

Rec. n/a n/a n/a


97





4.6.2 June 2009


IEC also requests that BTC/BIL provide additional information regarding VOC monitoring at the CMT and how VOC emissions will be compliant with project Standards.

Rec. A detailed VOC monitoring study was completed in 2009 which confirmed compliance with emissions standards and also does not require continuous emissions monitoring system (which was a local regulatory issue).

CLOSED

4.6.2 June 2009


IEC is pleased to note that the project intends to address both monitoring of groundwater and surface water quality, as stated by July 2009. However, the information provided during the June 2009 audit is not sufficient to address questions such as; at which facilities will groundwater monitoring be conducted, how groundwater characterization of each site will be undertaken, what new monitoring wells will be installed in addition to existing water wells, what parameters will be sampled, the sampling frequency and reporting procedures, etc.

Rec. IEC requests that BTC clarify groundwater monitoring procedures for each specific facility and that these procedures are consistent with BP standards at other fixed facilities similar to those of the BTC project.

BIL has added groundwater monitoring framework to BIL Environmental Monitoring Programme in 2009 and will start implementing the monitoring framework in 2010. BIL also started developing groundwater monitoring procedure accordingly.

OPEN

4.6.2 June 2009


IEC notes BTC’s request to change the MOC at the CMT regarding a reception facility for the treatment of slops and awaits additional information in this regard, when available.

Rec. BTC Co. has developed a MARPOL compliance strategy and submitted a report to Turkish Government for consent as of end 2009. A response is awaited from Turkish Government in 2010. The outcome will drive the scope of the change to the MOC.

OPEN

4.7.1 June 2009

BVT30 Incident BTC has taken a proactive approach to limit the environmental consequences of the BVT30 incident since it occurred. This includes a combination of approaches including a) immediate delineation and removal of contaminated material b) ongoing delineation studies and monitoring c) safe containment of contaminated material d) resolving all landowner issues relating to the incident. Phase 1 and Phase 2 studies have been completed. BTC is now focusing on two initiatives a) treatment of contaminated material currently stored on site and b) ongoing monitoring to determine the extent of in-situ contamination and consideration of remedial options.

Rec. It is recommended that BTC prepare a remediation and monitoring strategy to inform the Lenders as to how any residual liabilities resulting from the incident will be mitigated.

Reconstruction, further site clean-up, monitoring and soil disposal actions were all completed by end 2009. A summary document will be available in 2010.

OPEN


98





4.8.2 June 2009

Erosion Control, Reinstatement and Biorestoration

In June 2009, IEC notes much progress has been made toward establishing an effective ROW management system since the last audit, in particular regarding development of an integrated operational methodology for ROW problem identification and solution. Major erosion and landslides, reinstatement and biorestoration issues were effectively addressed in the last 12 months.

Rec. Considering that the post-construction ROW reinstatement has progressively achieved, the 2009/2010 activities on the ROW will mainly focus on maintenance aspects. However, further steps are required in order to fully achieve the objectives set out in the ESAP Commitments Register.

Post-construction ROW reinstatement actions were completed in Lot A and B in 2009. An extensive geohazard focused ROW maintenance programme was implemented in 2009. BIL has improved ROW monitoring and reporting system. These actions will continue in 2010.

OPEN

4.8.2 June 2009


As the ROW Register is intended to provide the most comprehensive and effective ROW mana-gement tool, it is recommended that environ-mental data entry into the BIMS are regularly recorded to ensure that monitoring data is updated on a current and consistent basis.

Rec. BIL has assigned a dedicated staff for data entry and reporting and further improved their database. The system will be tested in 2010.

OPEN

4.8.2 June 2009


Several tools to ensure adequate ROW maintenance and safe pipeline operations have been implemented or are presently under development. In 2009, the ROW maintenance management system is mainly based on the Patrol Teams reporting activities for the short term and routine monitoring purposes, on the remote sensing/satellite imagery analysis for a ROW trend analysis monitoring purposes, while geohazard analysis approach provides the areas of intervention assessment and ranking. The reinstatement/maintenance teams carry out the actual remedial works.

Rec. IEC noted that in spite of the multiple tool approach, a unified and integrated management system has not been developed yet.

A well coordinated management system is in operations rather than unified and integrated one. BIL has roles and responsibilities defined for ROW management which is based on coordination among respective teams.

OPEN

4.8.2 June 2009


IEC suggests that it would be useful to develop a fully integrated ROW maintenance manage-ment system that makes full use of available resour-ces and available data. This would allow the implementation of effective operating proce-dures for an action management system that goes beyond the problem identification, to provide a coordinated action response, speci-fying needed timeline and resources, in parti-cular those cases where ROW maintenance and reinstatement works are contracted to external company. The coordinated management system could take the form of an integrated web based database or other management tool, remotely accessible and easy to update and consult.

Rec. BIL has improved their GIS system with the support from BTC Co. The GIS system is planned to be the central information source in the near future and linked to ROW register.

OPEN


99





4.8.2 June 2009


Monitoring system of the five identified active fault zones has yet to be implemented. Fencing of the ROW - fault zone crossing has been completed, but the monitoring strategy/scope of work for the potentially high risk active faulting areas has not been defined.

Rec. IEC recommends BIL to further develop an active fault zone monitoring strategy that also includes site specific geological studies.

BTC Co. and BIL started to work on fault zone monitoring issues in 2009.

OPEN

4.8.4 June 2009

Access Roads IEC recognizes the successful efforts of BTC and BIL to deal with access road reinstatement and closure, arising from the construction phase.

Rec. IEC recommends that the coordinated transition from the BTC access road register to BIL access road register for operations is finally achieved and the outstanding punch list closed.

Further reinstatement of access roads was completed in 2009. The update of access road was completed by end 2009 and the gaps were filled in.

CLOSED

4.8.4 June 2009

Access Roads IEC recommends that an access roads closure report be developed in conjunction with the reinstatement contractor to document the closure and reinstatement of access roads.

Rec. Access road register was updated in 2009; a summary report for access road reinstatement will be prepared in 2010.

OPEN

4.8.4 June 2009

Access Roads IEC recommends that BTC and BIL prepare an Operational Access Road Strategy and Plan. The Plan should consider also the BTC/BIL exit strategy for villagers, landowners and local authorities that request that some of new built or accidentally opened access roads remain open. In particular, the exit strategy should take into consideration the liability aspects connected to this issue.

Rec. BIL continued planning works for access road strategy in 2009.

OPEN

4.8.4 June 2009

Access Roads The previous Level II non-compliance (Reinstatement CCP, Commitment ID: 2) regarding the final reinstatement of project access roads is rescinded. IEC will review the status of operational access roads as part of the 2010 audit

Rec. n/a n/a n/a

4.8.4 June 2009

Access Roads IEC recommends that GIS based access road database is designed to interact with the general GIS web based ROW Management System.

Rec. It is not in the short-term plans to develop a GIS based access road database. First step will be to make the general GIS system of BIL functional and collect and process further information on the use and status of access roads

OPEN

4.9.2 June 2009

Ecological Management

IEC recommends that BIL intensify restoration and re-vegetation efforts in those habitats where natural conditions make the re-growth very slow.

Rec. Biorestoration workshop was held between BTC Co., BIL and external consultants to develop guidelines for biological methods to support ROW vegetation cover. Biorestoration methods will start to be implemented in 2010 where necessary.

OPEN


100





4.10.2 June 2009

Community Liaison

In order to provide a full-time coverage and response to local communities and issues, BIL should fill the vacant PCRE position in Area 3.

Rec. As soon as BIL PCR Department is authorized to recruit new PCREs, appointments will be made to stations where back to back coverage is needed.

OPEN

4.10.2 June 2009

Community Liaison

In conjunction with the Lenders, BTC and BIL should identify procedures as to how livelihood assessment and other social evaluation procedures as currently undertaken by SRAP shall be carried out in future IEC audits.

Rec. SRAP panel visited Turkey and qualitative survey conducted in July. Statisticians completed additional data assessment requested by the SRAP panel. North part of SRAP report drafted and actions noted. Second part of the final report is awaited from SRAP.

OPEN

4.13.2 June 2009

H&S IEC recommends that BTC and BIL work together to ensure that an adequate safety oversight, supervision and training be provided to all employees and to third party personnel for both fixed facility and pipeline operations.

Rec. We believe that such an assurance exists and BTC Co. further increased the level of assurance over project contractors in 2009.

CLOSED

4.13.2 June 2009

H&S IEC recommends that adequate and regular workplace monitoring systems be implemented for major pollutants at fixed facilities where relevant, including noise, VOCs and BTEX. Additionally, IEC requests clarification from BTC/BIL as to how the project is undertaking measures to protect workers and those using accommodation areas at the CMT and fixed facilities.

Rec. Environmental and workplace noise monitoring were completed in 2009. The results were compliant. Relevant documentation will be provided to IEC in 2010 audit. H&S reviews of facilities accommodation areas are being conducted on a yearly basis, identified findings are recorded and actioned.

OPEN


101

APPENDIX 4: STATUS OF RECOMMENDATIONS RAISED THROUGH SRAP MONITORING

Appendix 4 contains the following for Azerbaijan, Georgia and Turkey:

Status of key recommendations raised during previous SRAP visits that were open at the time of the 2008 annual report (see Table A4.1);

The tables provide a transparent mechanism to demonstrate follow-up and close out of all actions to address the recommendations. The table shows that all SRAP recommendations have been closed and countries reported readiness for SRAP completion audit. In accordance with the audit scope, each country has selected the contractor to do the quantitative survey. After completion of quantitative survey SRAP panel have undertaken qualitative survey as part of the completion audit in 2009-Q3. The final completion report would outline the Project performance against social commitments.

Full reports from the SRAP audits are available on www.bp.com/caspian.

Table A4.1: Tracking of Recommendations from Previous Reviews

No Date Recommendation Status as of end December 2009

1 April 2008 BP to compensate landowners interested by orphan land transactions against the cost of registering the remaining piece of their land (Azerbaijan only)

Ongoing

2 April 2008 SRAP Panel to re-assess effectiveness of measures to improve EPPD understanding of pipeline land use restrictions during its autumn review.

Turkey - completed

3 April 2008 Consider transferring responsibility for implementation of the Employment and Training Management Plan from the Social Team to the Human Relations Department.

Turkey- Completed

4 April 2008 BTC/BP to commission a mid-term evaluation of CIP-2 not later than Spring, 2009.

Azerbaijan - Completed

Georgia - Completed.

5 April 2008 BTC to update tabulations of project affected landowners and users experiencing permanent loss of land and for each affected owner/user, to define the extent of those losses relative to his or her total landholding.

Azerbaijan - Ongoing

Georgia – Completed

Turkey-Completed

6 April 2008 BTC to undertake a survey of households affected by permanent loss of land in 2008 to verify whether or not each household has been able to restore its income. In the case of Georgia, a strategy should at least be in place by 2008 for doing this.



Turkey - Completed

7 April 2008 BTC to consider additional livelihood restoration measures for permanent land losers if the survey above establishes that livelihoods are not adequately restored.



Turkey - Completed

8 April 2008 Continued vigilance is required by BTC Co./BP in Georgia and Azerbaijan to ensure that the important role of the security of the pipeline is carried out in a manner which is appropriate and not antagonistic towards the communities

Azerbaijan - Ongoing


Turkey - Completed

9 April 2008 BTC Co. and Botaş/DSA to monitor the number of outstanding compensation cases against a stable total number of parcels and to provide evidence that the number of such is under control and decreasing (Turkey only)

Completed

10 April 2008 BIL to ensure that during the early years of Operations, Zilyet villages are carefully observed so that potential tensions within the villages can be managed. (Turkey only)

Completed

http://www.bp.com/caspian


102


11 April 2008 Land owners/users whose names and second crop areas were assessed by BTC Co. and Botaş/DSA should be paid second crop compensation, unless third party investigation by BNB gives clear, reasoned alternative recommendations. (Turkey only)

Completed

12 April 2008 BTC Co. to carry out a rigorous analysis of the current situation with the communities around the CMT including Gölovasi fishermen (incorporating stakeholder dynamics assessment of power and influence inter-play both within the fishing community and outside) and develop a strategy for a way forward. (Turkey only)

Completed

13 April 2008 BTC Co. to ensure that reinstatement related issues are reflected adequately in the grievance mechanism (Turkey only)

Completed

14 April 2008 BIL to develop a formal mechanism for transfer of information to new land users on land use restrictions which would incorporate written information to be passed on to the new land user. (Turkey only)

Completed

15 April 2008 BIL to complete introductory and follow-up meetings in all villages ASAP. (Turkey only)

Completed

16 April 2008 BIL to review mechanisms through which they can be reached by the community (including through telephone lines) and ensure that these are effective and functioning. (Turkey only)

Completed

17 April 2008 BIL to resolve current resource constraints (personnel and vehicle) in a perspective of increasing field presence and visibility. (Turkey only)

Ongoing

18 April 2008 BIL to refresh villagers’ awareness about avenues available to lodge grievances. (Turkey only)

Completed

19 April 2008 BTC Co. with BNB as independent monitors to ensure the quality assurance of the grievance management system. (Turkey only)

Ongoing

20 April 2008 BIL to place somewhere visible within the villages, the number of people employed in each village. (Turkey only)

Ongoing

21 April 2008 BIL to train unskilled employees to take up semi-skilled jobs. (Turkey only)

Ongoing

22 April 2008 BTC Co. and BIL to explore and identify supply chain opportunities for local firms. (Turkey only)

Ongoing

23 April 2008 BTC Co. and BIL to provide targeted support and capacity building to local firms to take up supply chain opportunities (BTC Co. already doing this to a certain extent but should increase efforts). (Turkey only)

Ongoing

24 June 2007 SRAP Panel to provide a cross country framework for livelihood restoration surveys to assure a level of consistency in approach.

Ongoing

25 June 2007 BTC Co. to undertake a survey of households affected by permanent loss of land in 2008 to verify whether or not each household has been able to restore its income. In the case of Georgia, a strategy should at least be in place by 2008 for doing this.



Turkey - Completed

26 June 2007 BTC Co. to consider additional livelihood restoration measures for permanent land losers if the survey above establishes that livelihoods are not adequately restored.

Completed

27 June 2007 In all three countries, BTC Co. to develop action plans to address/manage situations in which the landowner refuses to sign the land hand-back agreements.

Turkey- Completed

28 June 2007 In all three countries, BTC Co. to develop a management plan that will ensure that land acquisition in Operations phase is also carried out following World Bank Group OD 4/30 principles.

Completed


103


29 June 2007 Regular checks to be made on CIP I infrastructure to ensure that they are being properly managed and maintained.

Azerbaijan – Completed

Turkey-Completed

30 June 2007 BTC Co. to undertake a pragmatic social risk assessment for the Operations phase, and to design within the Operations CIP, proactive measures to address identified risks, particularly – but not only – in communities located near permanent installations such as pumping stations and terminals (Carried over from previous review)

Ongoing

In Turkey each project has a special strategy for AGI affected villages

31 June 2007 BTC Co./BP to provide training to security force patrol staff in Georgia and Azerbaijan on conduct along the pipeline as well as general human rights issues.


Turkey - Completed

32 September 2006

BTC to make stakeholders aware of avenues available to lodge complaints during Operations (Carried over from previous review).



Turkey – Completed

33 September 2005

Annual replicate income-expenditure surveys to be superseded by a one-off income-expenditure survey to be designed and overseen by the SRAP Panel, and conducted as part of the resettlement completion audit.

Completed. Report is awaited from SRAP panel

(Action on SRAP)

34 September 2005

All countries to pay particular attention to monitoring livelihood status of households affected by permanent loss of land. Annual income-expenditure surveys recommended.


Georgia – Ongoing


35 September 2005

To avoid ad hoc or piecemeal development assistance, BP Business Unit to look at designing the CIP strategy within a broader framework such as national poverty strategies (to the extent that these provide clear direction), or within a context of district or sub-district development plans


Georgia - Completed


36 September 2005

BTC to give consideration to adopting a labour standard based on an internationally recognized code or standard, to be applicable to all supply chain contracts with regular monitoring of compliance. (carried over from previous review).

Turkey- Ministry of Labour conducted employment standards audit in Turkey.

37 March 2005 BTC to look at avenues to incorporate small scale procurement and supply opportunities (e.g. incentives or quotas fostering village level content, re-bundling of procurement contracts) for villages in Georgia and Azerbaijan as part of its Operations Phase procurement strategy.

Ongoing

38 February 2004

BTC to continue to reinforce its anti-corruption stance with all levels of government.

Turkey- completed


104

APPENDIX 5: FINDINGS AND KEY RECOMMENDATIONS OF POLARIS AUDIT

Appendix 5 contains a summary of Polaris audit findings and key recommendations in relation to Oil Spill Readiness Assurance Review undertaken on behalf of the Lenders in October 2009.

The key finding of the OSR audit are:

BTC has maintained and improved its oil spill readiness capability relative to the findings of the 2007 OSR audit

Corporate commitment to spill readiness is evident in the policies implemented for sustained capability

BTC has maintained action tracking and implemented a number of recommendations from earlier audits and from feedback from responses and exercises

SEACOR teams have maintained a high level of response preparedness (vigorous exercise schedule, OSR base and equipment maintenance)

IMT and OSR contractors are nearly 100% comprised of nationals

OSR equipment has been added at bases (Tuckers, MANN trucks, skimmers, boom vanes, oil-water separators, field command post trailers etc.)

The Azerbaijan response programme is in a transition phase, with a strong response capability that is expected to improve further as the new team at PSA 2 gains experience.

Key recommendations are:

Completion of OSR base at PSG1, including development of a wildlife rehabilitation centre, and transition from Rustavi

Completion of secondary containment structures for the Georgia Special Response Area, including protocols for their use in emergencies

Careful review and alignment between OSR plans and the IMT manual, particularly concerning structures and roles in incident command

Vigorous training and field deployment efforts to bring the OSR response capability in Azerbaijan up to the level of Georgia OSR teams as they transition into a new role and responsibilities. It will take some time for the newly recruited PSA 2 team to gain experience and confidence and it would be better to be patient and we would recommend that this team rely initially on leadership support from the Baku base rather than push the new team too quickly

Assure IMT and field OSR exercises are integrated per the exercise schedule, including debriefings and reports

Add a robust inland spill response training programme to the IMT training requirements

Add spill source control and on-land response to spill scenarios and exercises

Recommend one annual Tier 2 exercise in each country for IMT and OSR teams that implements several nearly concurrent actions: source control, 1st downstream containment site and, 2nd containment site

Connect OSR bases at Tsalka and Borjomi to the national electricity grid and to external piped-in water supplies with existing generators and water tanks as backup systems

Invite Auditors external to the project to participate in a Tier 2 (transboundary or other) exercise design and evaluation.

Remnants of everyday life 3,000 years ago in the Caspian region have gone on display for the first time at a BP-operated

education centre. Cooking utensils and jewellery dating from the Bronze Age are among the items featured at a new

permanent exhibition called "Pipelines awaken ancient history" in the Caspian Energy Centre (CEC), based at the Sangachal

terminal in Azerbaijan. Unearthed during the construction of the Baku-Tbilisi-Ceyhan (BTC) and South Caucasus pipelines, the

artefacts are teaching local schoolchildren and university students about the lifestyle and skills of their ancestors.

The exhibition’s design, content and educational programmes were developed by US based designer and curator and combines

an animated film, gallery with archaeological facts, historical timeline and artefacts, and a touch screen interactive game.

Total cost of this project is US $400,000.

The archaeological exhibition, which includes an illustrative book and

website, forms part of a wider culture and heritage project, and

displays the artefacts found along the length of the pipelines in all

three countries. The full programme will be launched in 2010. In the

meantime visitors to the Caspian Energy Centre have the opportunity

to view some of the items excavated in Azerbaijan.

“It was the biggest digging project in the country’s history,” explains

centre manager, Ismail Miriyev, who was the first Azerbaijani to

complete an internship in museum management at the famous

Smithsonian Institute in Washington D.C. “Archaeological work had

never been done in Azerbaijan on such a scale.”

The massive archaeological dig along the route of the 1,770-

kilometre pipeline resulted in the production of some 40 reports on

findings for the Azerbaijani section alone. Excavation work in

Georgia and Turkey yielded a similar quantity of valuable material.

Artefacts from Azerbaijan have remained in storage at Institute of Archaeology and Ethnography of National Academy of

Science of Azerbaijan in Baku, with ten pieces now on loan to the Energy Centre. It is hoped the new exhibition will offer an

introduction to archaeology which will inspire visitors to seek further knowledge at national museums. “Reaction from our

visitors – schoolchildren and their teachers – is very positive,” says Ulviyya Gadirova, one of the centre’s presenters. “They are

excited to see objects that were used by ancient people who lived here; it truly astonishes them.”

CASE STUDY 1

PIPELINES AWAKEN ANCIENT HISTORY IN AZERBAIJAN

The BTC/SCP ROW in Georgia required the removal of about 105ha of forest. For pipeline integrity and safety reasons the

centre of the pipeline ROW must be kept clear of trees and large shrubs, making it impractical to re-establish forests in their

original location. BTC therefore evaluated the possibility establishing forest “offsets”, either by planting new forests elsewhere

in Georgia or by restoring existing degraded forests.

These plans, which involved planting and

managing 230 ha over a 20 year period,

were discussed with the Georgia Ministry of

Environment. Out of these discussions arose

a more radical offset that would bring

substantial environmental and educational

benefits to Georgia in a far shorter time.

The Sataplia State Reserve is located near

Kutaisi and is of significant geological,

paleontological, speleological and botanical

interest, containing beautiful Colchian type

mixed forests, rare limestone caves and even

dinosaur footprints. It is one of the most popular tourist destinations in Georgia despite the current poor infrastructure.

The Sataplia State Reserve Infrastructure Development Project (SIDP), which has the enthusiastic support of the President of

Georgia and other key Government officials, will be a sympathetic development of this reserve. With the support of BP, an

exhibition and educational center will be built together with a conference hall. In addition the cave will be rehabilitated and lit,

whilst the dinosaur footprints will be preserved and protected.

Although the SIDP is a very different offset project from that originally envisaged it is a great example of how to enhance local

facilities whilst conserving the environment. BP has therefore committed to allocate $ 3.5 million in 2010 and 2011 towards the

project as part of its environmental offset programme in Georgia.

CASE STUDY 2

ECO-COMPENSATION IN GEORGIA

A key commitment of BTC Co. is to ensure that nobody living along the route of the pipeline is adversely affected by it and that livelihoods are fully restored. However, BTC Co. aims to go beyond mere mitigation by actively promoting development along the route through its Community Investment Programme (CIP). In the area around Ceyhan Marine Terminal (CMT) this programme is particularly focused on supporting fishermen and their communities.

During the operation phase of the terminal two fishing cooperatives (Gölovası and Yumurtalık Center) have been supported by BTC Co through the “Supporting Sustainable Livelihood of Fishermen Communities in the Yumurtalık Bay Project”. These cooperatives have a membership of 163 fishermen drawn from a community of approximately 700 households who benefited from these projects in the region.

Although this project provided direct support to fishing activities, for example by the renovation of fishing boats, its scope went far beyond this. It included the enhancement of local infrastructure and provision of training and income generating opportunities outside of the fishing industry. The activities supported by the project include:

Improvement of the social infrastructure:

Rehabilitation of Gölovası water system

Establishment of a Computer Laboratory and training for all school children as well as 60 local women

Support to Income generation activities:

Improvement of current fishing activities:

Fishing boat renovations

Establishment of fish storage facilities

Establishment of an artificial reef of 100 blocks to enhance the fish population in Yumurtalık Bay

Establishment of an office room for the Gölovası Cooperative

Vocational Training

Welding courses for 22 young male members of Fishermen community

Hairdressing courses for members of fishermen community

Callboy (seaman) certification for 37 fishermen

Support to small entrepreneurship

Establishment of olive orchards for 20 fishermen families

Support for improvement of fishermen pensions

Support for renovating a fish restaurant and coffee house, from which two fishermen families benefited

Technical support to Cooperatives management

Trainings were organized to build the capacity of Golovasi and Yumurtalık Fisheries cooperatives on:

Sustainable fishing techniques

Financial and legal requirements of cooperatives

Marketing of fisheries products

Legal regulations for fisheries

As a consequence of these CIP activities in the village the income of the people affected by the pipeline has increased and, more significantly, they have also acquired new skills to help them organise and develop their businesses.

These communities were amongst those where initial concerns over the rapid industrialization of the region were the greatest. However with the support of the CIP project these concerns have been addressed and a potentially conflicting relationship has been transformed into one of mutual trust and respect.

CASE STUDY 3

CREATING SUSTAINABLE LIVELIHOOD FOR

FISHERMEN COMMUNITIES IN CEYHAN

btc project environmental and social annual report (operations … · 7.3 training ... - carbon...

Documents